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 reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
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