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...
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
Note: It is a system-generated summary and is for quick reference only.