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 - validity of order u/s 148A(d) without granting time to the petitioner to file reply to the notice u/s 148A(b) - The matter is remanded back to the respondent-Assessing Officer to provide an opportunity of hearing to the petitioner as required under Section 148A(b) of the Act. - The High court emphasized the need for the assessee to be given a chance to respond to the show-cause notice, ensuring compliance with procedural fairness in the reassessment proceedings.
Reopening of assessment u/s 147 - validity of order u/s 148A(d) without granting time to the petitioner to file reply to the notice u/s 148A(b) - The matter is remanded back to the respondent-Assessing Officer to provide an opportunity of hearing to the petitioner as required under Section 148A(b) of the Act. - The High court emphasized the need for the assessee to be given a chance to respond to the show-cause notice, ensuring compliance with procedural fairness in the reassessment proceedings.
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