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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Extended period of Limitation - There is no obligation cast on the appellant to intimate the Department on each and every transaction. The appellant have filed regular returns with the Department and have maintained proper records. Further, the appellant have obtained statement of “cost of production‟ duly certified by the Cost Accountant - The elements of suppression, mis-statement, fraud, etc. are not coming out from the facts and circumstances.
Extended period of Limitation - There is no obligation cast on the appellant to intimate the Department on each and every transaction. The appellant have filed regular returns with the Department and have maintained proper records. Further, the appellant have obtained statement of “cost of production‟ duly certified by the Cost Accountant - The elements of suppression, mis-statement, fraud, etc. are not coming out from the facts and circumstances.
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