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...
Finalization of the provisional assessment - The High Court emphasized the need for expeditious conclusion of internal processes, particularly when all required documents were submitted by the petitioners. The failure to issue specific communications to the petitioners regarding any further requirements or compliances, coupled with the decision not to finalize the bills of entries, amounted to arbitrariness and abdication of duties by the concerned officers. In light of the above, the High Court directed the respondent to finalize the bills of entries within four weeks from the date of the judgment.
Finalization of the provisional assessment - The High Court emphasized the need for expeditious conclusion of internal processes, particularly when all required documents were submitted by the petitioners. The failure to issue specific communications to the petitioners regarding any further requirements or compliances, coupled with the decision not to finalize the bills of entries, amounted to arbitrariness and abdication of duties by the concerned officers. In light of the above, the High Court directed the respondent to finalize the bills of entries within four weeks from the date of the judgment.
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