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 assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not only the question of abatement but also determines the date from which the six-year limitation period should be calculated. - The High court analyzed the relevant legal provisions and case law, emphasizing the need to prevent prejudice to affected parties due to delayed proceedings. It concluded that the assessment orders were indeed barred by limitation, highlighting the unjustified delay in recording satisfaction. Considering the statutory limitation period and lapse of time for completing the assessment, the court quashed the assessment orders.
Validity of assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not only the question of abatement but also determines the date from which the six-year limitation period should be calculated. - The High court analyzed the relevant legal provisions and case law, emphasizing the need to prevent prejudice to affected parties due to delayed proceedings. It concluded that the assessment orders were indeed barred by limitation, highlighting the unjustified delay in recording satisfaction. Considering the statutory limitation period and lapse of time for completing the assessment, the court quashed the assessment orders.
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