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...
Section 122(1A) is construed to cover "any person" other than the taxable person where that person retained the benefit of the contravening transactions and acted at whose instance they were done; on that basis, partners of a firm can be proceeded against if those factual conditions are recorded. The provision is treated as complementary to Section 122(1), not as creating a new independent offence, so it may apply to transactions predating 1 January 2021 if the show-cause notice was issued after the provision came into force. The writ challenge was rejected, while the petitioners were left free to contest the factual findings before the Appellate Tribunal.
Section 122(1A) is construed to cover "any person" other than the taxable person where that person retained the benefit of the contravening transactions and acted at whose instance they were done; on that basis, partners of a firm can be proceeded against if those factual conditions are recorded. The provision is treated as complementary to Section 122(1), not as creating a new independent offence, so it may apply to transactions predating 1 January 2021 if the show-cause notice was issued after the provision came into force. The writ challenge was rejected, while the petitioners were left free to contest the factual findings before the Appellate Tribunal.
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