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...
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Method of communication of notice - The High Court examined the provisions of Section 282(1) of the Income Tax Act, 1961 and Rule 127(1) of the Income Tax Rules, 1962 regarding the method and manner of service of notice. - The Court concluded that communication of notice electronically should adhere strictly to the prescribed methods and does not include presumptive notification by placing it on the e-portal. - The Court ruled in favor of the petitioner, stating that they were not given a fair opportunity to respond to the proceedings under Section 12A(1)(ac)(iii) of the Act of 1961.
Method of communication of notice - The High Court examined the provisions of Section 282(1) of the Income Tax Act, 1961 and Rule 127(1) of the Income Tax Rules, 1962 regarding the method and manner of service of notice. - The Court concluded that communication of notice electronically should adhere strictly to the prescribed methods and does not include presumptive notification by placing it on the e-portal. - The Court ruled in favor of the petitioner, stating that they were not given a fair opportunity to respond to the proceedings under Section 12A(1)(ac)(iii) of the Act of 1961.
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