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...
Validity of reopening of the case u/s. 147 - Reasons to believe - addition as unexplained cash credit u/s. 68 against sale of shares / investments along with share premium - The ITAT found that the reasons recorded for reopening were vague and lacked specificity, and the approval obtained was mechanical. Additionally, it concluded that the transactions in question were sales of shares held as investments, supported by evidence provided by the appellant. Consequently, the ITAT ruled in favor of the appellant, allowing the appeals and rejecting the additions made by the AO.
Validity of reopening of the case u/s. 147 - Reasons to believe - addition as unexplained cash credit u/s. 68 against sale of shares / investments along with share premium - The ITAT found that the reasons recorded for reopening were vague and lacked specificity, and the approval obtained was mechanical. Additionally, it concluded that the transactions in question were sales of shares held as investments, supported by evidence provided by the appellant. Consequently, the ITAT ruled in favor of the appellant, allowing the appeals and rejecting the additions made by the AO.
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