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...
Extension or rejection of the warehousing period under the sufficient-cause standard is quasi-judicial, requiring a judicial approach and an opportunity of hearing. The notes state that a denial must follow adjudicatory proceedings and be communicated through an appealable, reasoned order. Communications that merely convey rejection without findings or justification do not satisfy principles of natural justice. The Supreme Court's COVID-19 limitation extension is also noted. On the stated facts, the rejection communications were considered prima facie unsustainable; the matter was remanded for fresh adjudication after disclosure of proposed reasons, opportunity to reply and personal hearing, while consequential proceedings remained in abeyance.
Extension or rejection of the warehousing period under the sufficient-cause standard is quasi-judicial, requiring a judicial approach and an opportunity of hearing. The notes state that a denial must follow adjudicatory proceedings and be communicated through an appealable, reasoned order. Communications that merely convey rejection without findings or justification do not satisfy principles of natural justice. The Supreme Court's COVID-19 limitation extension is also noted. On the stated facts, the rejection communications were considered prima facie unsustainable; the matter was remanded for fresh adjudication after disclosure of proposed reasons, opportunity to reply and personal hearing, while consequential proceedings remained in abeyance.
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