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...
Rejection of SVLDRS-1 -Quantifiation of demand - It is evident that there was a quantification by the audit Department on 31.05.2019 based on which the petitioner has filed Form SVLDRS-1 dated 07.11.2019 under the category "Investigation, Enquiry or Audit" Subcategory Audit. It cannot therefore be construed that there was no determination of tax liability of the petitioner on or before 30.06.2019. - Application directed to be accepted. - HC
Rejection of SVLDRS-1 -Quantifiation of demand - It is evident that there was a quantification by the audit Department on 31.05.2019 based on which the petitioner has filed Form SVLDRS-1 dated 07.11.2019 under the category "Investigation, Enquiry or Audit" Subcategory Audit. It cannot therefore be construed that there was no determination of tax liability of the petitioner on or before 30.06.2019. - Application directed to be accepted. - HC
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