Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Addition on account of difference in Arm’s Length Price - characterization of the business function of the taxpayer - When the taxpayer is not proved to be a risk bearer in the nature of credit risk, price risk, inventory risk, storage and handling risk etc., it cannot be treated as a trader. - AT
Addition on account of difference in Arm’s Length Price - characterization of the business function of the taxpayer - When the taxpayer is not proved to be a risk bearer in the nature of credit risk, price risk, inventory risk, storage and handling risk etc., it cannot be treated as a trader. - AT
Note: It is a system-generated summary and is for quick reference only.