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...
Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds for considering an order as erroneous and prejudicial to the interests of the revenue - The tribunal found the section 263 order to be unjustifiable for multiple reasons, including the absence of a clear failure by the assessee to disclose fully and truly all material facts necessary for its assessment, and quashed the order. - Revision order quashed.
Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds for considering an order as erroneous and prejudicial to the interests of the revenue - The tribunal found the section 263 order to be unjustifiable for multiple reasons, including the absence of a clear failure by the assessee to disclose fully and truly all material facts necessary for its assessment, and quashed the order. - Revision order quashed.
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