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...
HC allowed the petition, invalidating the reassessment notice. The court determined that the Assessing Officer lacked sufficient material to demonstrate income escaping assessment exceeding Rs. 50 lacs in AY 2013-14. The notice was found to be beyond the prescribed limitation period under Section 149(1)(a) and did not satisfy conditions under Section 149(1)(b). The court specifically noted no evidence of undisclosed transactions or income, rendering the reassessment notice procedurally and substantively unsustainable. Consequently, the impugned order and notice were set aside, providing relief to the assessee.
HC allowed the petition, invalidating the reassessment notice. The court determined that the Assessing Officer lacked sufficient material to demonstrate income escaping assessment exceeding Rs. 50 lacs in AY 2013-14. The notice was found to be beyond the prescribed limitation period under Section 149(1)(a) and did not satisfy conditions under Section 149(1)(b). The court specifically noted no evidence of undisclosed transactions or income, rendering the reassessment notice procedurally and substantively unsustainable. Consequently, the impugned order and notice were set aside, providing relief to the assessee.
Note: It is a system-generated summary and is for quick reference only.