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...
Assessment u/s 153A - Validity of search proceedings - validity of the order of transfer passed u/s 127 - The ground taken by the petitioner of pendency of the litigation in the Allahabad High Court is of no assistance since the cause raised therein is regarding legality and validity of the order of transfer passed u/s 127 of the IT Act. Assuming without admitting that the said petition is allowed by the Allahabad High Court, even then the search and seizure operation which led to the passing of impugned order herein would not be adversely affected. More so, Allahabad High Court has not granted any interim order in favour of the petitioner. - HC
Assessment u/s 153A - Validity of search proceedings - validity of the order of transfer passed u/s 127 - The ground taken by the petitioner of pendency of the litigation in the Allahabad High Court is of no assistance since the cause raised therein is regarding legality and validity of the order of transfer passed u/s 127 of the IT Act. Assuming without admitting that the said petition is allowed by the Allahabad High Court, even then the search and seizure operation which led to the passing of impugned order herein would not be adversely affected. More so, Allahabad High Court has not granted any interim order in favour of the petitioner. - HC
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