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...
Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original assessment proceedings. It observed that the impugned notice was issued based on the same issue already considered during the original assessment and lacked any fresh tangible material for reopening. The High Court held that the Assessing Officer failed to assume jurisdiction to issue the notice, especially considering that it was issued after four years from the end of the assessment year and after the framing of the original assessment.
Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original assessment proceedings. It observed that the impugned notice was issued based on the same issue already considered during the original assessment and lacked any fresh tangible material for reopening. The High Court held that the Assessing Officer failed to assume jurisdiction to issue the notice, especially considering that it was issued after four years from the end of the assessment year and after the framing of the original assessment.
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