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...
Under the new reassessment regime, where the AO's own determination showed alleged escaped income below the prescribed threshold, a notice under section 148 could not be issued after three years from the end of the relevant assessment year. The Tribunal also held that prior approval under section 151 is a jurisdictional precondition and must be obtained from the authority prescribed for the applicable time limit. As the notice was issued beyond the permissible period and without valid compliance with sections 149 and 151, the notice and the resulting reassessment were void in law and were quashed.
Under the new reassessment regime, where the AO's own determination showed alleged escaped income below the prescribed threshold, a notice under section 148 could not be issued after three years from the end of the relevant assessment year. The Tribunal also held that prior approval under section 151 is a jurisdictional precondition and must be obtained from the authority prescribed for the applicable time limit. As the notice was issued beyond the permissible period and without valid compliance with sections 149 and 151, the notice and the resulting reassessment were void in law and were quashed.
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