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 - reasons to believe - The Appellate Tribunal scrutinized the reasons recorded for the reopening of the assessment and found several discrepancies. Firstly, it was noted that the AO incorrectly stated that the assessee claimed expenses on the amortization of goodwill, which was contradicted by the assessee's computation of total income and balance sheet. Additionally, the Tribunal observed that the AO overlooked the previous assessment completed under section 143(3) r.w.s. 153C of the Act. The Tribunal concluded that the reopening of the assessment was invalid and without jurisdiction. Consequently, the Tribunal allowed the appeal of the assessee on legal grounds.
Validity of reopening of assessment - reasons to believe - The Appellate Tribunal scrutinized the reasons recorded for the reopening of the assessment and found several discrepancies. Firstly, it was noted that the AO incorrectly stated that the assessee claimed expenses on the amortization of goodwill, which was contradicted by the assessee's computation of total income and balance sheet. Additionally, the Tribunal observed that the AO overlooked the previous assessment completed under section 143(3) r.w.s. 153C of the Act. The Tribunal concluded that the reopening of the assessment was invalid and without jurisdiction. Consequently, the Tribunal allowed the appeal of the assessee on legal grounds.
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