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...
Seeking review of order - error apparent on the face of record or not - The court acknowledged the existence of the amendment to Paragraph 9.3 of the Handbook of Procedures and recognized its relevance to the case. However, it concluded that the amendment had been duly considered in the earlier order, and there was no error apparent on the face of the record regarding its application. In line with the respondents' argument, the court emphasized that a review cannot be used as a disguised appeal. It cited a Supreme Court decision that cautioned against exceeding jurisdiction in review applications and reiterated the principle that a review cannot reevaluate evidence already considered in the main petition.
Seeking review of order - error apparent on the face of record or not - The court acknowledged the existence of the amendment to Paragraph 9.3 of the Handbook of Procedures and recognized its relevance to the case. However, it concluded that the amendment had been duly considered in the earlier order, and there was no error apparent on the face of the record regarding its application. In line with the respondents' argument, the court emphasized that a review cannot be used as a disguised appeal. It cited a Supreme Court decision that cautioned against exceeding jurisdiction in review applications and reiterated the principle that a review cannot reevaluate evidence already considered in the main petition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
