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...
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Under section 73, a summary in Form DRC-01 cannot replace the statutory show cause notice, and notice, statement and order must be issued and authenticated by the proper officer. The text notes that non-compliance makes the initiation ineffective, leading to quashing of the order in original while preserving the summary already issued and allowing a fresh notice. For de novo proceedings, the fresh notice relates back to the date of the summary, and the intervening period is excluded while computing limitation for passing the adjudication order.
Under section 73, a summary in Form DRC-01 cannot replace the statutory show cause notice, and notice, statement and order must be issued and authenticated by the proper officer. The text notes that non-compliance makes the initiation ineffective, leading to quashing of the order in original while preserving the summary already issued and allowing a fresh notice. For de novo proceedings, the fresh notice relates back to the date of the summary, and the intervening period is excluded while computing limitation for passing the adjudication order.
Note: It is a system-generated summary and is for quick reference only.
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