Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
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...
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Reopening of assessment u/s 147 - Notice issued on the basis of statement recorded during survey u/s 133A - The High court observed that the survey conducted led to several factual findings essential for initiating the proceedings u/s 148A. It was noted that the statement of one of the partners, was not the sole basis for the proceedings and that other evidence arising from the survey was also considered. The court also acknowledged that a statement was recorded under Section 131, which has the same powers as a civil court, including examining individuals under oath. - Consequently, High Court refused to interfere.
Reopening of assessment u/s 147 - Notice issued on the basis of statement recorded during survey u/s 133A - The High court observed that the survey conducted led to several factual findings essential for initiating the proceedings u/s 148A. It was noted that the statement of one of the partners, was not the sole basis for the proceedings and that other evidence arising from the survey was also considered. The court also acknowledged that a statement was recorded under Section 131, which has the same powers as a civil court, including examining individuals under oath. - Consequently, High Court refused to interfere.
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