Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Validity of reopening of assessment u/s 147 - opportunity of being heard by assessee by issuing the show cause notice u/s 148A(b) need to be given - The minimum seven days required to be made as a mandatory requirement and failure to comply with would render a notice itself invalid. Therefore, on this ground alone, the notice requires to be quashed and set aside. - HC
Validity of reopening of assessment u/s 147 - opportunity of being heard by assessee by issuing the show cause notice u/s 148A(b) need to be given - The minimum seven days required to be made as a mandatory requirement and failure to comply with would render a notice itself invalid. Therefore, on this ground alone, the notice requires to be quashed and set aside. - HC
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