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...
Where the assessee has opted not to appear before the ld. Pr. CIT nor before this Tribunal and has merely filed the appeal but has not pursued the appeal so filed by it and in the given situation where we are unable to lay our hands on any of the details of the financial transactions carried out by the assessee during the year and whether such transactions have been examined by ld. AO in the manner directed by ld. Pr. CIT passed u/s 263 we fail to find any infirmity in the finding of the ld. Pr. CIT in the impugned order - AT
Where the assessee has opted not to appear before the ld. Pr. CIT nor before this Tribunal and has merely filed the appeal but has not pursued the appeal so filed by it and in the given situation where we are unable to lay our hands on any of the details of the financial transactions carried out by the assessee during the year and whether such transactions have been examined by ld. AO in the manner directed by ld. Pr. CIT passed u/s 263 we fail to find any infirmity in the finding of the ld. Pr. CIT in the impugned order - AT
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