Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Section 213(b) requires recorded satisfaction, reasons showing application of mind, and a reasonable opportunity of hearing before an investigation into company affairs, or preliminary steps towards it, is directed. Requests to external investigative agencies for tracking information at the initial stage cannot proceed without a rational basis, compliance with those statutory conditions, and prior hearing of affected parties. Directions issued without these safeguards are contrary to natural justice and require fresh consideration after hearing the affected party.
Section 213(b) requires recorded satisfaction, reasons showing application of mind, and a reasonable opportunity of hearing before an investigation into company affairs, or preliminary steps towards it, is directed. Requests to external investigative agencies for tracking information at the initial stage cannot proceed without a rational basis, compliance with those statutory conditions, and prior hearing of affected parties. Directions issued without these safeguards are contrary to natural justice and require fresh consideration after hearing the affected party.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
