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...
Limitation Period for issuance of notice u/s 143(2) - Scrutiny Assessment - Relevant date - after filing of the return of income, defect notice u/s 139(9) had been sent to the assessee which was cured by the assessee - The ITAT allowed the appeal, holding that the notice issued under Section 143(2) beyond the prescribed time limit rendered the assessment order without jurisdiction and thus, it was quashed. The decision emphasized that the limitation for issuing such a notice runs from the year in which the return of income is filed and not from when a defect, if any, is rectified by the assessee.
Limitation Period for issuance of notice u/s 143(2) - Scrutiny Assessment - Relevant date - after filing of the return of income, defect notice u/s 139(9) had been sent to the assessee which was cured by the assessee - The ITAT allowed the appeal, holding that the notice issued under Section 143(2) beyond the prescribed time limit rendered the assessment order without jurisdiction and thus, it was quashed. The decision emphasized that the limitation for issuing such a notice runs from the year in which the return of income is filed and not from when a defect, if any, is rectified by the assessee.
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