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...
Power of Tribunal to enhance the tax liability - The Tribunal is an independent adjudicatory authority having jurisdiction to determine the liability to pay tax. Under the Act it has no power to enhance the liability to pay tax determined by the taxing authorities. Where sufficient material exists on record the Tribunal is expected to decide the matter, on merits. It has no power to pass an order of remand only because it is of the opinion that a higher tax liability ought to be imposed although revenue has decided not to prefer any appeal against the determination of tax liability. - HC
Power of Tribunal to enhance the tax liability - The Tribunal is an independent adjudicatory authority having jurisdiction to determine the liability to pay tax. Under the Act it has no power to enhance the liability to pay tax determined by the taxing authorities. Where sufficient material exists on record the Tribunal is expected to decide the matter, on merits. It has no power to pass an order of remand only because it is of the opinion that a higher tax liability ought to be imposed although revenue has decided not to prefer any appeal against the determination of tax liability. - HC
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