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...
Validity of reopening of assessment - Validity of grant the approval by the PCIT - relevancy of information reported by Insight portal - Despite the petitioner's explanations and evidence of proper accounting, the Assessing Officer issued an impugned order claiming significant income escapement. However, the Court found discrepancies between the notice and the order, highlighting the AO's limited authority to reassess income based solely on the issues raised in the notice. Ultimately, the Court allowed the petition, quashing both the impugned order and notice.
Validity of reopening of assessment - Validity of grant the approval by the PCIT - relevancy of information reported by Insight portal - Despite the petitioner's explanations and evidence of proper accounting, the Assessing Officer issued an impugned order claiming significant income escapement. However, the Court found discrepancies between the notice and the order, highlighting the AO's limited authority to reassess income based solely on the issues raised in the notice. Ultimately, the Court allowed the petition, quashing both the impugned order and notice.
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