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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Validity of order of ITAT allowing Applications filed u/s 254(2) - Rectification versus Review of order - TP Adjustment - The High court observed that the ITAT had rendered incompatible and inconsistent findings in its original order. - The court noted a contradiction between paragraphs 12 and 21 of the original order. - It was deemed necessary for the ITAT to recall its previous order and correct the error to avoid leaving the TPO and Assessing Officer in a quandary. - The court found that the issue of comparability regarding one company was left open for the ITAT's consideration, while another company's matter was remitted to the TPO. - Ultimately, the court determined that the appeal of Revenue did not raise any substantial question of law and dismissed it accordingly.
Validity of order of ITAT allowing Applications filed u/s 254(2) - Rectification versus Review of order - TP Adjustment - The High court observed that the ITAT had rendered incompatible and inconsistent findings in its original order. - The court noted a contradiction between paragraphs 12 and 21 of the original order. - It was deemed necessary for the ITAT to recall its previous order and correct the error to avoid leaving the TPO and Assessing Officer in a quandary. - The court found that the issue of comparability regarding one company was left open for the ITAT's consideration, while another company's matter was remitted to the TPO. - Ultimately, the court determined that the appeal of Revenue did not raise any substantial question of law and dismissed it accordingly.
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