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...
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
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