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...
Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
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