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...
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
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