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...
Unexplained foreign bank credits were remanded for fresh consideration because the assessee had not received an effective opportunity to submit supporting evidence on their source. The notes state that pending criminal financial-offence proceedings, custody, and detention under a look-out notice justified granting one further opportunity in the interests of justice. The appellate order was set aside, and the Commissioner (Appeals) was directed to reconsider the credits after providing a proper hearing and allowing supporting evidence to be furnished.
Unexplained foreign bank credits were remanded for fresh consideration because the assessee had not received an effective opportunity to submit supporting evidence on their source. The notes state that pending criminal financial-offence proceedings, custody, and detention under a look-out notice justified granting one further opportunity in the interests of justice. The appellate order was set aside, and the Commissioner (Appeals) was directed to reconsider the credits after providing a proper hearing and allowing supporting evidence to be furnished.
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