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...
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
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