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 Re-assessment proceedings u/s 147 - Earlier the notice for Assessment u/s 153A/C was issued - denying deduction u/s 80IB - The High Court observed that the impugned reopening notice was based on the same issue that was subject to appeal, which led to the order dated 30th March 2015 by the CIT(A). The Court cited the third proviso to Section 147 of the Act, which prohibits reassessment of income involving matters that are the subject of any appeal, reference, or revision.
Validity of Re-assessment proceedings u/s 147 - Earlier the notice for Assessment u/s 153A/C was issued - denying deduction u/s 80IB - The High Court observed that the impugned reopening notice was based on the same issue that was subject to appeal, which led to the order dated 30th March 2015 by the CIT(A). The Court cited the third proviso to Section 147 of the Act, which prohibits reassessment of income involving matters that are the subject of any appeal, reference, or revision.
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