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...
Scope of SCN - The argument that the original authority has confirmed a higher amount on grounds which are not alleged in the SCN and has thus traversed beyond the SCN is not without substance. There is also no evidence available from the impugned order or from the records that SCN and the OIO have been served on the appellant. The said plea has been put forward by the appellant from the very beginning of the litigation. - AT
Scope of SCN - The argument that the original authority has confirmed a higher amount on grounds which are not alleged in the SCN and has thus traversed beyond the SCN is not without substance. There is also no evidence available from the impugned order or from the records that SCN and the OIO have been served on the appellant. The said plea has been put forward by the appellant from the very beginning of the litigation. - AT
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