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...
Under the statutory scheme for draft assessments, filing objections before the Dispute Resolution Panel requires the Faceless Assessing Officer to keep assessment proceedings in abeyance until the Panel issues directions. A final assessment cannot be made after objections have been filed and the Transfer Pricing Officer has been informed, but before those objections are decided. The final assessment order and consequential demand notice were quashed, while the pending Dispute Resolution Panel proceedings remained unaffected and may be followed by further action in accordance with law.
Under the statutory scheme for draft assessments, filing objections before the Dispute Resolution Panel requires the Faceless Assessing Officer to keep assessment proceedings in abeyance until the Panel issues directions. A final assessment cannot be made after objections have been filed and the Transfer Pricing Officer has been informed, but before those objections are decided. The final assessment order and consequential demand notice were quashed, while the pending Dispute Resolution Panel proceedings remained unaffected and may be followed by further action in accordance with law.
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