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 dealt with a case involving a Revision u/s 263. The PCIT alleged that the AO did not inquire into cash deposits during demonetization or non-disclosure of income from scrap sales. However, the ITAT found that the AO had conducted proper inquiries based on assessment records, notices issued u/s 142(1), and replies from the assessee. The PCIT's allegations were deemed unfounded as the assessment order was not erroneous or prejudicial to revenue. The ITAT emphasized that invoking section 263 requires meeting specific conditions and that the revisionary authority cannot act arbitrarily. The decision favored the assessee due to lack of evidence supporting the PCIT's allegations.
The ITAT dealt with a case involving a Revision u/s 263. The PCIT alleged that the AO did not inquire into cash deposits during demonetization or non-disclosure of income from scrap sales. However, the ITAT found that the AO had conducted proper inquiries based on assessment records, notices issued u/s 142(1), and replies from the assessee. The PCIT's allegations were deemed unfounded as the assessment order was not erroneous or prejudicial to revenue. The ITAT emphasized that invoking section 263 requires meeting specific conditions and that the revisionary authority cannot act arbitrarily. The decision favored the assessee due to lack of evidence supporting the PCIT's allegations.
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