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...
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
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