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...
Writ petition challenging reopening of assessment u/s 147 for income chargeable u/s 5(2) rejected. Petitioner failed to establish with documentary evidence husband's non-resident Indian status and genuineness of sources of funds transferred from NRE account to domestic account. Court reluctant to interfere in assessment orders under Article 226 when effective alternative remedy available, especially involving disputed questions of fact. Petitioner granted liberty to file appeal within three weeks from order copy receipt, without limitation objection, subject to compliance with appeal conditions including pre-deposit, if any. Merits not examined, observation limited to maintainability of writ petition.
Writ petition challenging reopening of assessment u/s 147 for income chargeable u/s 5(2) rejected. Petitioner failed to establish with documentary evidence husband's non-resident Indian status and genuineness of sources of funds transferred from NRE account to domestic account. Court reluctant to interfere in assessment orders under Article 226 when effective alternative remedy available, especially involving disputed questions of fact. Petitioner granted liberty to file appeal within three weeks from order copy receipt, without limitation objection, subject to compliance with appeal conditions including pre-deposit, if any. Merits not examined, observation limited to maintainability of writ petition.
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