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...
Assessment u/s 153A - completed assessments to be interfered with by the A.O. while making the assessment u/s 153A - The Tribunal upheld the decision of the Ld. CIT(A) in deleting the addition. - The ITAT reiterated the principle that completed assessments can only be interfered with by the AO under Section 153A based on incriminating material found during the search. Since the revenue failed to demonstrate that the additions were made on such basis, the court found no reason to interfere with the order of the Ld. CIT(A).
Assessment u/s 153A - completed assessments to be interfered with by the A.O. while making the assessment u/s 153A - The Tribunal upheld the decision of the Ld. CIT(A) in deleting the addition. - The ITAT reiterated the principle that completed assessments can only be interfered with by the AO under Section 153A based on incriminating material found during the search. Since the revenue failed to demonstrate that the additions were made on such basis, the court found no reason to interfere with the order of the Ld. CIT(A).
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