Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
TPA - the assessee cannot seek to raise an issue before the Tribunal in respect of which he has not filed any objection before the Dispute Resolution Panel nor has the Dispute Resolution Panel considered the issue in exercise of their powers u/s 144C(8) - AT
TPA - the assessee cannot seek to raise an issue before the Tribunal in respect of which he has not filed any objection before the Dispute Resolution Panel nor has the Dispute Resolution Panel considered the issue in exercise of their powers u/s 144C(8) - AT
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