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...
Immunity u/s 270AA - Period of limitation for filing an application - Penalty proceedings u/s 270A - The proviso to Sub-section(4) of Section 270AA of the Act makes it amply clear that before an application is rejected, the applicant must be given an opportunity of being heard. In the present case, there is no dispute that the petitioner was not afforded the said opportunity. - AO directed to reconsider the application - HC
Immunity u/s 270AA - Period of limitation for filing an application - Penalty proceedings u/s 270A - The proviso to Sub-section(4) of Section 270AA of the Act makes it amply clear that before an application is rejected, the applicant must be given an opportunity of being heard. In the present case, there is no dispute that the petitioner was not afforded the said opportunity. - AO directed to reconsider the application - HC
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