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...
A composite show cause notice under Section 74 covering multiple tax periods or financial years was held impermissible. The HC relied on its earlier rulings to hold that clubbing distinct tax periods in one proceeding creates a jurisdictional defect, and a notice issued on that basis is illegal. Because the foundational show cause notice was invalid, the consequential Order-in-Original could not survive and was set aside. Liberty was reserved to initiate fresh proceedings in accordance with law, with all contentions kept open.
A composite show cause notice under Section 74 covering multiple tax periods or financial years was held impermissible. The HC relied on its earlier rulings to hold that clubbing distinct tax periods in one proceeding creates a jurisdictional defect, and a notice issued on that basis is illegal. Because the foundational show cause notice was invalid, the consequential Order-in-Original could not survive and was set aside. Liberty was reserved to initiate fresh proceedings in accordance with law, with all contentions kept open.
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