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...
The HC held that the AO did not independently verify the material on record or form an opinion that income escaped assessment due to the assessee's failure to disclose facts. The reopening was based on borrowed satisfaction from information received without independent application of mind. Merely relying on information from other sources without forming an independent opinion is impermissible for reassessment proceedings. The HC decided in favour of the assessee.
The HC held that the AO did not independently verify the material on record or form an opinion that income escaped assessment due to the assessee's failure to disclose facts. The reopening was based on borrowed satisfaction from information received without independent application of mind. Merely relying on information from other sources without forming an independent opinion is impermissible for reassessment proceedings. The HC decided in favour of the assessee.
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