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...
Reopening of assessment - reasons to believe - On the issue of disclosure and compliance with TDS provisions, the court found that the petitioner had indeed disclosed all material facts during the original assessment proceedings. The transactions in question were merely transfers of funds on instructions from the horse owners. - The court held that the objections raised by the petitioner against the reassessment were valid. The authorities had failed to consider the full scope of the disclosures made during the original assessments and erroneously pursued reassessment.
Reopening of assessment - reasons to believe - On the issue of disclosure and compliance with TDS provisions, the court found that the petitioner had indeed disclosed all material facts during the original assessment proceedings. The transactions in question were merely transfers of funds on instructions from the horse owners. - The court held that the objections raised by the petitioner against the reassessment were valid. The authorities had failed to consider the full scope of the disclosures made during the original assessments and erroneously pursued reassessment.
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