Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
The adjudicating authority has lost sight of the fact that the appellant's company is an artificial or non-human entity, cannot function or operate without involvement of the natural person i.e. the directors or the authorized persons. Therefore, we are of the considered view that the charges of guilt of 'collusion', 'wilful misstatement' or 'suppression of facts' cannot be levelled against the appellant, justifying invocation of the provisions of Section 28AAA of the Act - AT
The adjudicating authority has lost sight of the fact that the appellant's company is an artificial or non-human entity, cannot function or operate without involvement of the natural person i.e. the directors or the authorized persons. Therefore, we are of the considered view that the charges of guilt of 'collusion', 'wilful misstatement' or 'suppression of facts' cannot be levelled against the appellant, justifying invocation of the provisions of Section 28AAA of the Act - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
