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 the Assessing Officer (AO) lacked valid jurisdictional grounds for reopening the assessment. Despite having territorial jurisdiction, the AO failed to establish a substantive reason to believe income had escaped assessment. The notice was deemed invalid as it was based solely on information from an insight portal without concrete evidence connecting the alleged accommodation entries to the petitioner's audited accounts. The court found the reopening notice constituted a fishing inquiry without demonstrating a prima facie case of income escaping assessment, thereby rendering the reopening notice legally untenable and unsustainable.
HC held that the Assessing Officer (AO) lacked valid jurisdictional grounds for reopening the assessment. Despite having territorial jurisdiction, the AO failed to establish a substantive reason to believe income had escaped assessment. The notice was deemed invalid as it was based solely on information from an insight portal without concrete evidence connecting the alleged accommodation entries to the petitioner's audited accounts. The court found the reopening notice constituted a fishing inquiry without demonstrating a prima facie case of income escaping assessment, thereby rendering the reopening notice legally untenable and unsustainable.
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