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...
Reopening of assessment u/s 147 - reasons to believe - bogus transaction - It has been held that even in the reasons recorded when there is no allegation that there was any failure on the part of the assessee in not disclosing truly and fully material facts necessary for the assessment, the assumption of jurisdiction to reopen the assessment beyond a period of four years in exercise of powers under Section 147 of the Act is bad in law and contrary to the provisions of Section 137. - HC
Reopening of assessment u/s 147 - reasons to believe - bogus transaction - It has been held that even in the reasons recorded when there is no allegation that there was any failure on the part of the assessee in not disclosing truly and fully material facts necessary for the assessment, the assumption of jurisdiction to reopen the assessment beyond a period of four years in exercise of powers under Section 147 of the Act is bad in law and contrary to the provisions of Section 137. - HC
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