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...
Relaxation under the FTP for genuine hardship requires a meaningful, reasoned consideration of the exporter's specific case, and administrative orders affecting rights must disclose cogent reasons rather than mechanical conclusions. The Court found that the authorities failed to address the claimed technical non-transmission of authorisation data, the asserted fulfilment of export obligations, and repeated requests for relief, and also denied a personal hearing despite specific requests. On that basis, the orders were set aside for non-application of mind and breach of natural justice, and the matter was remanded for fresh consideration with an effective hearing and a reasoned order.
Relaxation under the FTP for genuine hardship requires a meaningful, reasoned consideration of the exporter's specific case, and administrative orders affecting rights must disclose cogent reasons rather than mechanical conclusions. The Court found that the authorities failed to address the claimed technical non-transmission of authorisation data, the asserted fulfilment of export obligations, and repeated requests for relief, and also denied a personal hearing despite specific requests. On that basis, the orders were set aside for non-application of mind and breach of natural justice, and the matter was remanded for fresh consideration with an effective hearing and a reasoned order.
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