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...
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
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