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 requested virtual hearing in faceless income-tax appellate proceedings is integral to the opportunity to be heard under principles of natural justice. Written submissions and the memorandum of appeal cannot replace an oral or personal hearing, whether physical or virtual. Where no video-conferencing link was communicated and the requested hearing was not afforded, the appellate process resulted in failure of justice. The High Court set aside the appellate order, restored the appeal for a fresh hearing with video-conferencing facility, and quashed consequential penalty orders, subject to fresh action after disposal of the restored appeal.
A requested virtual hearing in faceless income-tax appellate proceedings is integral to the opportunity to be heard under principles of natural justice. Written submissions and the memorandum of appeal cannot replace an oral or personal hearing, whether physical or virtual. Where no video-conferencing link was communicated and the requested hearing was not afforded, the appellate process resulted in failure of justice. The High Court set aside the appellate order, restored the appeal for a fresh hearing with video-conferencing facility, and quashed consequential penalty orders, subject to fresh action after disposal of the restored appeal.
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