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 assessment made u/s 147 instead of u/s. 153C - Addition as unexplained cash credit u/s. 68 - Upon examination, the ITAT Delhi found that the seized material, along with statements by involved parties, constituted incriminating evidence, warranting proceedings under section 153C. Citing precedent from various judicial decisions, the ITAT Delhi concluded that the failure to follow the procedure under section 153C invalidated the reassessment under section 147/148. Consequently, the ITAT Delhi upheld the decision of the CIT(A) to quash the reassessment.
Validity of assessment made u/s 147 instead of u/s. 153C - Addition as unexplained cash credit u/s. 68 - Upon examination, the ITAT Delhi found that the seized material, along with statements by involved parties, constituted incriminating evidence, warranting proceedings under section 153C. Citing precedent from various judicial decisions, the ITAT Delhi concluded that the failure to follow the procedure under section 153C invalidated the reassessment under section 147/148. Consequently, the ITAT Delhi upheld the decision of the CIT(A) to quash the reassessment.
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