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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Validity of Reopening of assessment - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC
Validity of Reopening of assessment - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC
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