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...
Validity of assessment u/s 153A regarding unexplained cash credits u/s 68, absence of incriminating material found during search proceedings, and lack of valid approval u/s 153D. The key points are: the assessment proceedings were unabated when the search was conducted; no incriminating material pertaining to the assessment year was found during the search to justify additions u/s 68; statements recorded before or after the search cannot be considered incriminating material; mere observation about investors' financials cannot constitute incriminating material; in the absence of incriminating material, additions cannot be made for unabated assessments; the Assessing Officer continued assessment proceedings and modified the draft order after forwarding it for approval u/s 153D, resulting in material variance from the approved draft order; the final order was passed without valid approval as required u/s 153D, rendering it unsustainable.
Validity of assessment u/s 153A regarding unexplained cash credits u/s 68, absence of incriminating material found during search proceedings, and lack of valid approval u/s 153D. The key points are: the assessment proceedings were unabated when the search was conducted; no incriminating material pertaining to the assessment year was found during the search to justify additions u/s 68; statements recorded before or after the search cannot be considered incriminating material; mere observation about investors' financials cannot constitute incriminating material; in the absence of incriminating material, additions cannot be made for unabated assessments; the Assessing Officer continued assessment proceedings and modified the draft order after forwarding it for approval u/s 153D, resulting in material variance from the approved draft order; the final order was passed without valid approval as required u/s 153D, rendering it unsustainable.
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