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...
The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being based on borrowed satisfaction without proper enquiry. The AO noted discrepancies in LTCG disclosure and re-assessed income u/s 147. However, the Tribunal found the AO's actions flawed, as the assessee had disclosed exempt income in Schedule-EI. The AO's lack of independent satisfaction led to quashing of the assessment, citing Meenakshi Overseas (P) Ltd. The appeal of the assessee was allowed.
The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being based on borrowed satisfaction without proper enquiry. The AO noted discrepancies in LTCG disclosure and re-assessed income u/s 147. However, the Tribunal found the AO's actions flawed, as the assessee had disclosed exempt income in Schedule-EI. The AO's lack of independent satisfaction led to quashing of the assessment, citing Meenakshi Overseas (P) Ltd. The appeal of the assessee was allowed.
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