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 Tribunal cannot condition remand for breach of natural justice on payment of costs so that default automatically validates an invalid ex parte appellate order. Although it may impose ordinary procedural costs, its discretion cannot defeat the statutory right of appeal or make the remedy illusory; the automatic-confirmation clause was quashed and the appeal restored unconditionally for merits adjudication. A first appellate authority must issue a speaking order stating the points for determination, decision and reasons; the non-speaking ex parte order was void. For the unsecured-loan addition, banking and corporate records required proper factual evaluation, and general third-party reports without independent inquiry were insufficient; the issue was remanded for fresh adjudication.
A Tribunal cannot condition remand for breach of natural justice on payment of costs so that default automatically validates an invalid ex parte appellate order. Although it may impose ordinary procedural costs, its discretion cannot defeat the statutory right of appeal or make the remedy illusory; the automatic-confirmation clause was quashed and the appeal restored unconditionally for merits adjudication. A first appellate authority must issue a speaking order stating the points for determination, decision and reasons; the non-speaking ex parte order was void. For the unsecured-loan addition, banking and corporate records required proper factual evaluation, and general third-party reports without independent inquiry were insufficient; the issue was remanded for fresh adjudication.
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