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...
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
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