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 High Court considered the validity of reassessment notices issued u/s 148 of the Income Tax Act, 1961 in light of the Finance Act, 2021. It was held that the reassessment process should have complied with the provisions of the Finance Act, 2021, as per a previous decision. The Court found that the respondent-Department's actions were in contravention of the Finance Act, 2021 and directives from the Supreme Court. Therefore, the notices and subsequent proceedings were deemed illegal and quashed. The consequential orders passed by the respondent Department were also nullified due to the procedural errors in initiating the proceedings. The Court set aside the Show Cause notices and orders, allowing both parties to proceed as per the law.
The High Court considered the validity of reassessment notices issued u/s 148 of the Income Tax Act, 1961 in light of the Finance Act, 2021. It was held that the reassessment process should have complied with the provisions of the Finance Act, 2021, as per a previous decision. The Court found that the respondent-Department's actions were in contravention of the Finance Act, 2021 and directives from the Supreme Court. Therefore, the notices and subsequent proceedings were deemed illegal and quashed. The consequential orders passed by the respondent Department were also nullified due to the procedural errors in initiating the proceedings. The Court set aside the Show Cause notices and orders, allowing both parties to proceed as per the law.
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