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...
Rationalisation of Appeals to the Appellate Tribunal - as per the amendment to sec 253 revisional order passed u/s 263 by PCC or CC or an order u/s 154 are now appealable to Appellate Tribunal. Also, Memorandum of cross objection has been introduced for the revenue where in case respondent files appeal against the order of Commissioner (Appeals), like Principal Commissioner or Commissioner or Principal Director or Director etc. AO would be able to file a cross objection to such appeal which cannot be filed presently.
Rationalisation of Appeals to the Appellate Tribunal - as per the amendment to sec 253 revisional order passed u/s 263 by PCC or CC or an order u/s 154 are now appealable to Appellate Tribunal. Also, Memorandum of cross objection has been introduced for the revenue where in case respondent files appeal against the order of Commissioner (Appeals), like Principal Commissioner or Commissioner or Principal Director or Director etc. AO would be able to file a cross objection to such appeal which cannot be filed presently.
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