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...
The reassessment proceeding shall be deemed completed only upon communication of the impugned assessment order to the assessee, not merely when the order was passed. The order cannot be considered passed unless pronounced, published, or the affected party has means of knowing it. Keeping the signed order in file without communicating is insufficient. The reassessment proceeding for AY 2003-2004 was completed on 05-04-2007 when the order was served, beyond the limitation period prescribed u/s 153(2). Availability of statutory appeal does not bar entertaining a writ petition under Article 226 in certain exceptions like violation of statutory provisions, natural justice, lack of jurisdiction, or pure legal controversy. The impugned assessment orders were quashed for violating section 153(2) of the Income Tax Act, 1961.
The reassessment proceeding shall be deemed completed only upon communication of the impugned assessment order to the assessee, not merely when the order was passed. The order cannot be considered passed unless pronounced, published, or the affected party has means of knowing it. Keeping the signed order in file without communicating is insufficient. The reassessment proceeding for AY 2003-2004 was completed on 05-04-2007 when the order was served, beyond the limitation period prescribed u/s 153(2). Availability of statutory appeal does not bar entertaining a writ petition under Article 226 in certain exceptions like violation of statutory provisions, natural justice, lack of jurisdiction, or pure legal controversy. The impugned assessment orders were quashed for violating section 153(2) of the Income Tax Act, 1961.
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