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...
Independent application of mind is required before a competent authority issues a show cause notice. The High Court noted that use of an artificial intelligence tool to prepare and issue the notice lacked demonstrated statutory sanction, and rejected the explanation that AI-generated references were inadvertently uploaded. As the authority had not independently examined the facts as required by the statute, the show cause notice and consequential proceedings were quashed. The authority retained liberty to initiate fresh action in accordance with law after independently applying its mind.
Independent application of mind is required before a competent authority issues a show cause notice. The High Court noted that use of an artificial intelligence tool to prepare and issue the notice lacked demonstrated statutory sanction, and rejected the explanation that AI-generated references were inadvertently uploaded. As the authority had not independently examined the facts as required by the statute, the show cause notice and consequential proceedings were quashed. The authority retained liberty to initiate fresh action in accordance with law after independently applying its mind.
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