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 Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
Validity of Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
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