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 - prior period of expenses - mercantile system of accounting - The petitioner argued that the reliance on the assessment order for AY 2010-2011 was unjustified since the Commissioner of Income Tax (Appeals) [CIT(A)] later allowed the prior period expenses for that year, and the Revenue accepted the CIT(A)'s order. The Income Tax Appellate Tribunal (ITAT) also upheld this position in a similar case. - The High court agreed with the petitioner and quashed the reassessment proceedings.
Reopening of assessment - prior period of expenses - mercantile system of accounting - The petitioner argued that the reliance on the assessment order for AY 2010-2011 was unjustified since the Commissioner of Income Tax (Appeals) [CIT(A)] later allowed the prior period expenses for that year, and the Revenue accepted the CIT(A)'s order. The Income Tax Appellate Tribunal (ITAT) also upheld this position in a similar case. - The High court agreed with the petitioner and quashed the reassessment proceedings.
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