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...
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The HC held that the Assessing Officer could not reopen the assessment for AY 2013-14 merely relying on information from the insight portal without forming an independent opinion based on the assessee's records. The assessee had disclosed and offered to tax the loss from F&O transactions, which was scrutinized and accepted during regular assessment. Reopening on the same issue amounts to a change of opinion, which is impermissible. The reopening lacked tangible material and application of mind, rendering it invalid. The Court decided in favor of the assessee.
The HC held that the Assessing Officer could not reopen the assessment for AY 2013-14 merely relying on information from the insight portal without forming an independent opinion based on the assessee's records. The assessee had disclosed and offered to tax the loss from F&O transactions, which was scrutinized and accepted during regular assessment. Reopening on the same issue amounts to a change of opinion, which is impermissible. The reopening lacked tangible material and application of mind, rendering it invalid. The Court decided in favor of the assessee.
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