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...
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
HC ruled that the block period of six years for reassessment under Section 153C(1)(b) is to be calculated from 28.07.2022. The extended ten-year period is inapplicable in this case. The jurisdictional notice for Assessment Year 2016-17, falling beyond the six-year block period, was deemed unsustainable. Relying on prior judicial precedent, the court set aside the impugned notice, effectively invalidating the tax department's attempt to reopen the assessment beyond the prescribed statutory timeframe.
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