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...
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
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