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...
An ex parte revision order under section 263 was held unsustainable because the assessee received only one day to respond to the show-cause notice, which was treated as denial of a reasonable opportunity of hearing and a breach of audi alteram partem. By majority, the Tribunal held that the defect was procedural and curable, so the revision proceedings were not terminated; the impugned order was set aside and the matter remanded for fresh adjudication after adequate opportunity, uninfluenced by observations on merits.
An ex parte revision order under section 263 was held unsustainable because the assessee received only one day to respond to the show-cause notice, which was treated as denial of a reasonable opportunity of hearing and a breach of audi alteram partem. By majority, the Tribunal held that the defect was procedural and curable, so the revision proceedings were not terminated; the impugned order was set aside and the matter remanded for fresh adjudication after adequate opportunity, uninfluenced by observations on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
