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...
Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
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