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...
Unsigned approval under section 151 for reassessment was treated as invalid because section 282A(1) requires electronic tax documents to be signed. Following its earlier rulings, the ITAT held that this signature requirement is mandatory; where the approval bore no signature, it was void ab initio. As the foundational approval itself was unlawful, the reassessment proceedings based on it could not survive and the assessment was unsustainable.
Unsigned approval under section 151 for reassessment was treated as invalid because section 282A(1) requires electronic tax documents to be signed. Following its earlier rulings, the ITAT held that this signature requirement is mandatory; where the approval bore no signature, it was void ab initio. As the foundational approval itself was unlawful, the reassessment proceedings based on it could not survive and the assessment was unsustainable.
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