Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
An Assessing Officer who is bound by earlier remand directions must adjudicate the original show cause notice after granting personal hearing and considering the reply; issuing a second show cause notice instead is treated as impermissible overreaching of the prior court order. The note states that the impugned adjudication was set aside and the matter remanded for fresh decision on the first show cause notice in compliance with natural justice under Section 75(4).
An Assessing Officer who is bound by earlier remand directions must adjudicate the original show cause notice after granting personal hearing and considering the reply; issuing a second show cause notice instead is treated as impermissible overreaching of the prior court order. The note states that the impugned adjudication was set aside and the matter remanded for fresh decision on the first show cause notice in compliance with natural justice under Section 75(4).
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