Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Writ jurisdiction against a reassessment order was declined because the Court found no abject denial of natural justice. A show cause notice under section 148 had been issued, the assessee filed replies raising legal and merits-based objections, the Department satisfactorily explained supply of documents with the notice, and the Assessing Authority considered the reply before finalising the assessment. In these circumstances, the availability of an efficacious statutory appeal under the Act barred interference under Article 226. The assessee was therefore required to pursue the assessment challenge before the appellate forum.
Writ jurisdiction against a reassessment order was declined because the Court found no abject denial of natural justice. A show cause notice under section 148 had been issued, the assessee filed replies raising legal and merits-based objections, the Department satisfactorily explained supply of documents with the notice, and the Assessing Authority considered the reply before finalising the assessment. In these circumstances, the availability of an efficacious statutory appeal under the Act barred interference under Article 226. The assessee was therefore required to pursue the assessment challenge before the appellate forum.
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