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...
Suppressed production or not - loss of material - The assessee had itself produced voluminous evidence. This is not a case where the Assessing Officer had caught the assessee by surprise. There may be minor discrepancy or inaccurate recording of non-essential facts by the CIT(A) and the Tribunal. However, the same would not vitiate the very order or shake the foundation of their orders.
Suppressed production or not - loss of material - The assessee had itself produced voluminous evidence. This is not a case where the Assessing Officer had caught the assessee by surprise. There may be minor discrepancy or inaccurate recording of non-essential facts by the CIT(A) and the Tribunal. However, the same would not vitiate the very order or shake the foundation of their orders.
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