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 r.w.s. 148A(b) - Petitioner claimed that despite certain transactions being booked under the PAN of erstwhile company (amalgamated company) due to an error, they had correctly considered all transactions in their return. - The court found merit in the petitioner's contention regarding the lack of proper application of mind in granting approval under Section 151. They observed discrepancies in the approval process, indicating a failure to review the request and draft order adequately. Consequently, the court deemed it appropriate to quash the order under Section 148A(d) of the Act and the consequent notice issued under Section 148.
Validity of reopening of assessment u/s 147 r.w.s. 148A(b) - Petitioner claimed that despite certain transactions being booked under the PAN of erstwhile company (amalgamated company) due to an error, they had correctly considered all transactions in their return. - The court found merit in the petitioner's contention regarding the lack of proper application of mind in granting approval under Section 151. They observed discrepancies in the approval process, indicating a failure to review the request and draft order adequately. Consequently, the court deemed it appropriate to quash the order under Section 148A(d) of the Act and the consequent notice issued under Section 148.
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