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...
Proceedings before the CIT after transfer / posting - proceedings are continuous, merely because on change of incumbent, fresh show cause notice was issued, it cannot be construed to mean that it is fresh show cause notice especially in view of the fact that there is no evidence on record to show that earlier show cause notice was dropped. Thus, the appellant himself is responsible for delay in culminating the proceedings into the final order. Appeal filed by the assessee is dismissed. - AT
Proceedings before the CIT after transfer / posting - proceedings are continuous, merely because on change of incumbent, fresh show cause notice was issued, it cannot be construed to mean that it is fresh show cause notice especially in view of the fact that there is no evidence on record to show that earlier show cause notice was dropped. Thus, the appellant himself is responsible for delay in culminating the proceedings into the final order. Appeal filed by the assessee is dismissed. - AT
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