Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable.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the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable.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.
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