Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Dispute Resolution Panel directions bind the Assessing Officer when an eligible assessee files timely objections to a draft assessment order. A bona fide failure to separately intimate the Assessing Officer of those objections, where it causes no advantage or prejudice, does not justify ignoring the Panel's directions. Where the transfer-pricing order forming the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable. The final assessment, consequential demand and penalty-initiation notices were set aside, and the assessment was restored for fresh completion in conformity with the Panel's directions and revised transfer-pricing order.
Dispute Resolution Panel directions bind the Assessing Officer when an eligible assessee files timely objections to a draft assessment order. A bona fide failure to separately intimate the Assessing Officer of those objections, where it causes no advantage or prejudice, does not justify ignoring the Panel's directions. Where the transfer-pricing order forming the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable. The final assessment, consequential demand and penalty-initiation notices were set aside, and the assessment was restored for fresh completion in conformity with the Panel's directions and revised transfer-pricing order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4790
Join Channel
TaxTMI 
