Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
HC held that the validity of FERA show-cause notices issued after repeal turned on whether the issuing officer had legal authority under the repeal-and-savings scheme in FEMA. Relying on the earlier co-ordinate Bench ruling in First Global Stockbroking Pvt. Ltd. v. R.M. Ramchandani, the Court held that the same officer was not empowered to act as adjudicating officer for notices under the repealed enactment. As no stay of that ruling existed and no distinguishing facts were shown, the notices were found to be without jurisdiction and were quashed.
HC held that the validity of FERA show-cause notices issued after repeal turned on whether the issuing officer had legal authority under the repeal-and-savings scheme in FEMA. Relying on the earlier co-ordinate Bench ruling in First Global Stockbroking Pvt. Ltd. v. R.M. Ramchandani, the Court held that the same officer was not empowered to act as adjudicating officer for notices under the repealed enactment. As no stay of that ruling existed and no distinguishing facts were shown, the notices were found to be without jurisdiction and were quashed.
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