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 order passed u/s 153C/143(3) against Settlement Commission order - The Tribunal found the reassessment to infringe upon the principles laid out by the ITSC, which had already settled the income at 8% of the receipts from the water pipeline project. The reassessment was deemed impermissible in law, rendering the impugned order dated 30.12.2019 passed u/s 153C/153A/143(3) as invalid. Consequently, all additions made therein were deleted.
Validity of assessment order passed u/s 153C/143(3) against Settlement Commission order - The Tribunal found the reassessment to infringe upon the principles laid out by the ITSC, which had already settled the income at 8% of the receipts from the water pipeline project. The reassessment was deemed impermissible in law, rendering the impugned order dated 30.12.2019 passed u/s 153C/153A/143(3) as invalid. Consequently, all additions made therein were deleted.
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