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...
Jurisdiction of AO to issue notice u/s 143(2) - notice u/s 143(2) was issued by one AO and the assessment has been completed by another AO - The provisions of sub-section (4) of section 127 will be applicable only when there is an order under section 127 of the Act. Since the Department was not able to show any order passed under section 127 of the Act, this argument of the ld. Counsel for the assessee is also accepted. - AT
Jurisdiction of AO to issue notice u/s 143(2) - notice u/s 143(2) was issued by one AO and the assessment has been completed by another AO - The provisions of sub-section (4) of section 127 will be applicable only when there is an order under section 127 of the Act. Since the Department was not able to show any order passed under section 127 of the Act, this argument of the ld. Counsel for the assessee is also accepted. - AT
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