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...
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
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