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...
Benefit of Vivad se Vishwas Scheme - The High held that, once the respondents had taken the principled position that the VSV Act would apply even in those matters where the limitation period for filing of appeals had not expired on the specified date, there can be no valid justification to either countenance or draw a distinction between an appeal and a revision. The acceptance of such a distinction would be wholly illogical quite apart from being manifestly arbitrary and violative of Article 14 of the Constitution. - Since the petitioner has already deposited the entire disputed tax liability as computed in terms of the VSV Act, the Form 5 issued during the pendency of these proceedings is accorded finality.
Benefit of Vivad se Vishwas Scheme - The High held that, once the respondents had taken the principled position that the VSV Act would apply even in those matters where the limitation period for filing of appeals had not expired on the specified date, there can be no valid justification to either countenance or draw a distinction between an appeal and a revision. The acceptance of such a distinction would be wholly illogical quite apart from being manifestly arbitrary and violative of Article 14 of the Constitution. - Since the petitioner has already deposited the entire disputed tax liability as computed in terms of the VSV Act, the Form 5 issued during the pendency of these proceedings is accorded finality.
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