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...
Revision u/s 263 by CIT - The Appellate Tribunal found that the PCIT's assumption of jurisdiction under Section 263 was not justified. It observed that the assessment order was not erroneous, as the Assessing Officer had accepted the returned income and made no additions based on the reasons recorded for reopening the assessment. Therefore, the Tribunal set aside the PCIT's order and restored that of the Assessing Officer.
Revision u/s 263 by CIT - The Appellate Tribunal found that the PCIT's assumption of jurisdiction under Section 263 was not justified. It observed that the assessment order was not erroneous, as the Assessing Officer had accepted the returned income and made no additions based on the reasons recorded for reopening the assessment. Therefore, the Tribunal set aside the PCIT's order and restored that of the Assessing Officer.
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