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 Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.
Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.
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