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...
Validity of assessment order - reply to the ASTM-10 notice was not taken into consideration - violation of principles of natural justice - Acknowledging the importance of providing the petitioner with an opportunity to contest the tax demand on merits, the High Court decides to set aside the impugned order. However, this is conditional on the petitioner remitting 10% of the disputed tax demand within two weeks and submitting a reply to the show cause notice within the same period.
Validity of assessment order - reply to the ASTM-10 notice was not taken into consideration - violation of principles of natural justice - Acknowledging the importance of providing the petitioner with an opportunity to contest the tax demand on merits, the High Court decides to set aside the impugned order. However, this is conditional on the petitioner remitting 10% of the disputed tax demand within two weeks and submitting a reply to the show cause notice within the same period.
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