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 under old regime - scope of new regime - scope of TOLA - In this detailed judgement, the Court found that the notice issued under Section 148 was invalid due to its reliance on repealed provisions. The High Court noted that subsequent legislation and court decisions had overtaken the statutes on which the original notices were based, rendering them ineffective. The High Court pointed out procedural flaws in the reassessment process, including the lack of proper approval from designated authorities, which was mandated by the law. The court emphasized the importance of following due process to uphold the integrity of tax reassessment procedures.
Reopening of assessment under old regime - scope of new regime - scope of TOLA - In this detailed judgement, the Court found that the notice issued under Section 148 was invalid due to its reliance on repealed provisions. The High Court noted that subsequent legislation and court decisions had overtaken the statutes on which the original notices were based, rendering them ineffective. The High Court pointed out procedural flaws in the reassessment process, including the lack of proper approval from designated authorities, which was mandated by the law. The court emphasized the importance of following due process to uphold the integrity of tax reassessment procedures.
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