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...
Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section 50C, which is an interpretation of law and not 'information' required for reopening. The Assessing Officer's reasons recorded for reopening showed lack of reason to believe income escaped assessment, being mere reason to suspect based on change of opinion. Section 50C was held inapplicable to sale after conversion of capital asset into stock-in-trade, following precedents. The appeal was allowed in favor of the assessee.
Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section 50C, which is an interpretation of law and not 'information' required for reopening. The Assessing Officer's reasons recorded for reopening showed lack of reason to believe income escaped assessment, being mere reason to suspect based on change of opinion. Section 50C was held inapplicable to sale after conversion of capital asset into stock-in-trade, following precedents. The appeal was allowed in favor of the assessee.
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