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...
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Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
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