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...
Validity of reassessment proceedings - non-affording the petitioner an opportunity of being heard as mandated u/s 148A(b) - The court dismissed the Revenue's appeal, affirming the judgment of the learned Single Judge. It held that the requirement of providing an opportunity of being heard includes the right to a personal hearing, as mandated by Section 148A of the Income Tax Act. - The HC has also taken note of the amendment to the provisions of Section 148A(b) through the Finance Act, 2022 with effect from 1.4.2022.
Validity of reassessment proceedings - non-affording the petitioner an opportunity of being heard as mandated u/s 148A(b) - The court dismissed the Revenue's appeal, affirming the judgment of the learned Single Judge. It held that the requirement of providing an opportunity of being heard includes the right to a personal hearing, as mandated by Section 148A of the Income Tax Act. - The HC has also taken note of the amendment to the provisions of Section 148A(b) through the Finance Act, 2022 with effect from 1.4.2022.
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