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...
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
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