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 - Reason to believe - The notice was based on alleged undisclosed cash deposits made by the trust during a specific financial year. The trust objected to the reopening, arguing that all income was duly recorded and offered for taxation. The High court found that the reasons provided for reopening were unsubstantiated and lacked a rational connection to establish income escapement. It emphasized the impermissibility of fishing expeditions without concrete evidence. Consequently, the court set aside the notice of reopening.
Reopening of assessment u/s 147 - Reason to believe - The notice was based on alleged undisclosed cash deposits made by the trust during a specific financial year. The trust objected to the reopening, arguing that all income was duly recorded and offered for taxation. The High court found that the reasons provided for reopening were unsubstantiated and lacked a rational connection to establish income escapement. It emphasized the impermissibility of fishing expeditions without concrete evidence. Consequently, the court set aside the notice of reopening.
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