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...
HC held that under Sections 74(1), (2), and (10), each assessment year must be proceeded separately by the proper officer. The statutory time limit for issuing orders is distinct for each financial year. The court mandates independent show cause notices for different assessment years, recognizing that taxpayers can raise separate defenses for each year. The composite notice challenging jurisdictional propriety was partially set aside, with the notice for 2017-2018 sustained and notices for 2018-2019, 2019-2020, 2020-2021, and 2021-2022 quashed. The appellate court found the single judge's interpretation erroneous and allowed the appeal, emphasizing the need for precise, year-specific tax assessment procedures.
HC held that under Sections 74(1), (2), and (10), each assessment year must be proceeded separately by the proper officer. The statutory time limit for issuing orders is distinct for each financial year. The court mandates independent show cause notices for different assessment years, recognizing that taxpayers can raise separate defenses for each year. The composite notice challenging jurisdictional propriety was partially set aside, with the notice for 2017-2018 sustained and notices for 2018-2019, 2019-2020, 2020-2021, and 2021-2022 quashed. The appellate court found the single judge's interpretation erroneous and allowed the appeal, emphasizing the need for precise, year-specific tax assessment procedures.
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