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...
Validity of reopening of assessment - The High Court notes that certain incomes were raised for the first time in the impugned order, without prior mention. Despite Petitioner's explanations and evidence, the Assessing Officer (AO) failed to justify dissatisfaction with the disclosures. The Court concludes that the impugned order was passed without proper application of mind, as evident from the lack of scrutiny by higher authorities. Consequently, the Court quashes the impugned order and the notice issued under Section 148 of the Act.
Validity of reopening of assessment - The High Court notes that certain incomes were raised for the first time in the impugned order, without prior mention. Despite Petitioner's explanations and evidence, the Assessing Officer (AO) failed to justify dissatisfaction with the disclosures. The Court concludes that the impugned order was passed without proper application of mind, as evident from the lack of scrutiny by higher authorities. Consequently, the Court quashes the impugned order and the notice issued under Section 148 of the Act.
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