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...
Where a common adjudication order covers multiple noticees, a Bench should not entertain one noticee's appeal on merits merely because that noticee's office falls within its territorial limits. Applying forum non conveniens and its prior decision, the Tribunal said the proper course was to place the matter before the President under Notification No. 1/2022 for constitution of the appropriate Bench to hear all appeals from the same order, avoiding conflicting decisions, ensuring uniformity of fact and law, and keeping the matter under single High Court supervision.
Where a common adjudication order covers multiple noticees, a Bench should not entertain one noticee's appeal on merits merely because that noticee's office falls within its territorial limits. Applying forum non conveniens and its prior decision, the Tribunal said the proper course was to place the matter before the President under Notification No. 1/2022 for constitution of the appropriate Bench to hear all appeals from the same order, avoiding conflicting decisions, ensuring uniformity of fact and law, and keeping the matter under single High Court supervision.
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