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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Composite show cause notices covering multiple assessment years are not legally sustainable where separate notices are required for each year. Applying prior Division Bench rulings, the HC quashed the consolidated notice, while preserving the respondents' liberty to issue fresh notices for the relevant assessment years. It also directed that the period from issuance of the impugned notice until receipt of the certified copy of the judgment be excluded when computing limitation in any fresh proceedings.
Composite show cause notices covering multiple assessment years are not legally sustainable where separate notices are required for each year. Applying prior Division Bench rulings, the HC quashed the consolidated notice, while preserving the respondents' liberty to issue fresh notices for the relevant assessment years. It also directed that the period from issuance of the impugned notice until receipt of the certified copy of the judgment be excluded when computing limitation in any fresh proceedings.
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