Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
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...
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Validity of reopening of assessment questioned due to errors in original notice. Notice alleged non-filing of return, later contradicted. AO failed to evaluate return before alleging income escape. AO's opinion on income taxation not based on due process. DTAA benefits not part of original notice. Final order relied on assessment from prior year. Allotment of shares under scheme not considered. Reassessment reasons must be consistent. Petitioner refuted remittances, claimed DTAA exemption. AO's denial of treaty benefits without original basis not valid. Court ruled in favor of assessee, criticizing AO's inconsistent approach.
Validity of reopening of assessment questioned due to errors in original notice. Notice alleged non-filing of return, later contradicted. AO failed to evaluate return before alleging income escape. AO's opinion on income taxation not based on due process. DTAA benefits not part of original notice. Final order relied on assessment from prior year. Allotment of shares under scheme not considered. Reassessment reasons must be consistent. Petitioner refuted remittances, claimed DTAA exemption. AO's denial of treaty benefits without original basis not valid. Court ruled in favor of assessee, criticizing AO's inconsistent approach.
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