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...
Fraud-account classification requires a reasoned order showing due application of mind, although the reasons need not match the detail of a judicial judgment. The order identified grounds under the Fraud Master Circular and recorded audit findings on diversion of funds through an undisclosed account, related-party transactions, unjustified transfers and interest-free advances; it was therefore adequately reasoned. Natural justice was not breached because the petitioners had received and discussed the draft audit report, had opportunities to provide material, and received the final report with the show-cause notice. The HC dismissed the writ petition, upholding the fraud classification.
Fraud-account classification requires a reasoned order showing due application of mind, although the reasons need not match the detail of a judicial judgment. The order identified grounds under the Fraud Master Circular and recorded audit findings on diversion of funds through an undisclosed account, related-party transactions, unjustified transfers and interest-free advances; it was therefore adequately reasoned. Natural justice was not breached because the petitioners had received and discussed the draft audit report, had opportunities to provide material, and received the final report with the show-cause notice. The HC dismissed the writ petition, upholding the fraud classification.
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