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...
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
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