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...
Reassessment under section 148 requires prima facie material that can link the assessee to the alleged escaped income; the expressions "relates to" and "pertains to" in Explanation 2 cannot be read in isolation. The revenue must examine seized material with surrounding circumstances and record its relevance to the assessee. Where the relied-upon document is vague, unspecific, names another person, and is connected only by later collateral information, no live nexus is established. In such circumstances, reopening is based on conjecture and is unsustainable, and the reopening notices and consequential assessment orders are liable to be quashed.
Reassessment under section 148 requires prima facie material that can link the assessee to the alleged escaped income; the expressions "relates to" and "pertains to" in Explanation 2 cannot be read in isolation. The revenue must examine seized material with surrounding circumstances and record its relevance to the assessee. Where the relied-upon document is vague, unspecific, names another person, and is connected only by later collateral information, no live nexus is established. In such circumstances, reopening is based on conjecture and is unsustainable, and the reopening notices and consequential assessment orders are liable to be quashed.
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