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...
Principles of Natural justice - long delay of 13 years in adjudication of SCN - The grounds raised before the adjudicating authority as well as in this petition appear to be on merits. The issue of delay of 13 years in adjudicating the show cause notice can also be raised by the Petitioner in an appeal under section 35B of the Excise Act,1944 which provides for an appellate remedy against an order-in-original before the Tribunal. Neither there is any allegation nor the learned counsel has been able to demonstrate that there has been any breach of the principles of natural justice. - HC
Principles of Natural justice - long delay of 13 years in adjudication of SCN - The grounds raised before the adjudicating authority as well as in this petition appear to be on merits. The issue of delay of 13 years in adjudicating the show cause notice can also be raised by the Petitioner in an appeal under section 35B of the Excise Act,1944 which provides for an appellate remedy against an order-in-original before the Tribunal. Neither there is any allegation nor the learned counsel has been able to demonstrate that there has been any breach of the principles of natural justice. - HC
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