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...
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A revision under section 263 was sustained where the Assessing Officer had not made the enquiry and verification the scrutiny assessment required. The Tribunal noted that only generalized notices had been issued, with no real examination, follow-up enquiry or application of mind on the selected scrutiny issues, including expense claims, related-party payments and tax deduction defaults. It applied the principle that merely calling for details and filing them on record is not enough to constitute enquiry, and that Explanation 2(a) to section 263 applies when no proper view is formed after due examination. The assessee's contention that disclosure of details barred revision was rejected.
A revision under section 263 was sustained where the Assessing Officer had not made the enquiry and verification the scrutiny assessment required. The Tribunal noted that only generalized notices had been issued, with no real examination, follow-up enquiry or application of mind on the selected scrutiny issues, including expense claims, related-party payments and tax deduction defaults. It applied the principle that merely calling for details and filing them on record is not enough to constitute enquiry, and that Explanation 2(a) to section 263 applies when no proper view is formed after due examination. The assessee's contention that disclosure of details barred revision was rejected.
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