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...
An adjudicatory order must deal with the pleadings and record reasons for accepting or rejecting the reliefs sought; failure to consider the contentions raised and the remaining prayers renders the order non-speaking and vitiated for non-application of mind. As the impugned order granted only part of the relief without addressing the balance claims on merits, it was quashed and the application was remitted for fresh decision, without expressing any view on the underlying merits.
An adjudicatory order must deal with the pleadings and record reasons for accepting or rejecting the reliefs sought; failure to consider the contentions raised and the remaining prayers renders the order non-speaking and vitiated for non-application of mind. As the impugned order granted only part of the relief without addressing the balance claims on merits, it was quashed and the application was remitted for fresh decision, without expressing any view on the underlying merits.
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