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...
Validity of second SCN - invocation of Extended period of Limitation - it is found that the amount of interest under Section 28 AA demanded in the earlier show cause notice also, and the same was confirmed in the adjudication proceedings, which is presently subjudice before the Hon’ble Rajasthan High Court. Thus, in the present show cause notice, which is mainly for the demand of interest under Section 28 AA and also for a small amount of short tax paid for the same period, is bad for invocation of extended period of limitation. - AT
Validity of second SCN - invocation of Extended period of Limitation - it is found that the amount of interest under Section 28 AA demanded in the earlier show cause notice also, and the same was confirmed in the adjudication proceedings, which is presently subjudice before the Hon’ble Rajasthan High Court. Thus, in the present show cause notice, which is mainly for the demand of interest under Section 28 AA and also for a small amount of short tax paid for the same period, is bad for invocation of extended period of limitation. - AT
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