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...
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Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
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