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...
Applicability of the DTVSV Act - Eligibility or otherwise of the petitioner to avail benefit under the scheme - If time to file objections has not yet expired, the assessee can decide for settling the dispute under the scheme. Either ways, the benefit of the applicability of the DTVSV Act cannot be denied solely on the basis of the filing of objections or not. Thus, the acceptance of the said contention advanced by the respondent would make the clarification issued by the 3rd respondent vide answer to question No.16 of FAQs, otiose and redundant. - the DTVSV Act being a beneficial piece of legislation, resort should be made to liberal interpretation rather than literal interpretation, which would render the entire scheme inoperable. - HC
Applicability of the DTVSV Act - Eligibility or otherwise of the petitioner to avail benefit under the scheme - If time to file objections has not yet expired, the assessee can decide for settling the dispute under the scheme. Either ways, the benefit of the applicability of the DTVSV Act cannot be denied solely on the basis of the filing of objections or not. Thus, the acceptance of the said contention advanced by the respondent would make the clarification issued by the 3rd respondent vide answer to question No.16 of FAQs, otiose and redundant. - the DTVSV Act being a beneficial piece of legislation, resort should be made to liberal interpretation rather than literal interpretation, which would render the entire scheme inoperable. - HC
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