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...
Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions the decision-making process of the Principal Commissioner of Income Tax (PCIT). Despite the petitioner's objections to the accuracy of the information, the PCIT granted approval, indicating a potential lapse in due diligence or application of mind. - The court suggests that the CIT should have either declined approval or directed the Assessing Officer to address the petitioner's concerns adequately. - The court quashes and sets aside the impugned order and notice.
Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions the decision-making process of the Principal Commissioner of Income Tax (PCIT). Despite the petitioner's objections to the accuracy of the information, the PCIT granted approval, indicating a potential lapse in due diligence or application of mind. - The court suggests that the CIT should have either declined approval or directed the Assessing Officer to address the petitioner's concerns adequately. - The court quashes and sets aside the impugned order and notice.
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