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...
Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.
Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.
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