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...
Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
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