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...
Draft assessment repeated in the final order without incorporating DRP directions was held invalid, because directions under section 144C bind the Assessing Officer and the final assessment must conform to them. The Tribunal, following Olympus Medical Systems (P) Ltd., treated non-conformity with the DRP procedure as rendering the final assessment order bad in law and liable to be quashed. On that basis, the impugned order was quashed as null and void, and the remaining jurisdictional and merits grounds were left unadjudicated.
Draft assessment repeated in the final order without incorporating DRP directions was held invalid, because directions under section 144C bind the Assessing Officer and the final assessment must conform to them. The Tribunal, following Olympus Medical Systems (P) Ltd., treated non-conformity with the DRP procedure as rendering the final assessment order bad in law and liable to be quashed. On that basis, the impugned order was quashed as null and void, and the remaining jurisdictional and merits grounds were left unadjudicated.
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