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 u/s 147 - The petitioner had initially failed to file income tax returns but later submitted various documents in response to notices received under the Income Tax Act. Despite this, the assessment order did not consider the documents submitted by the petitioner, nor did it provide reasons for the proposed variations. The court set aside the impugned order and remanded the matter to the tax authorities for reconsideration.
Reopening of assessment u/s 147 - The petitioner had initially failed to file income tax returns but later submitted various documents in response to notices received under the Income Tax Act. Despite this, the assessment order did not consider the documents submitted by the petitioner, nor did it provide reasons for the proposed variations. The court set aside the impugned order and remanded the matter to the tax authorities for reconsideration.
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