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...
Validity of reopening proceedings - assessing authority not considering the reply-cum-objection filed by the petitioner - Period of limitation where monetary limit is below threshold of Rs. 50 lakhs - Joint Ownership of the property - The High Court quashed the entire enquiry proceeding, including the order under section 148A(d) of the Act and the notice issued under Section 148, deeming them beyond jurisdiction and barred by limitation. The court allowed the petitioner's application, emphasizing the procedural lapses and the incorrect application of the law by the tax department in this case.
Validity of reopening proceedings - assessing authority not considering the reply-cum-objection filed by the petitioner - Period of limitation where monetary limit is below threshold of Rs. 50 lakhs - Joint Ownership of the property - The High Court quashed the entire enquiry proceeding, including the order under section 148A(d) of the Act and the notice issued under Section 148, deeming them beyond jurisdiction and barred by limitation. The court allowed the petitioner's application, emphasizing the procedural lapses and the incorrect application of the law by the tax department in this case.
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