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...
Eligibility for settlement under DTVSV Act - Delay in filing appeal - Pending appeal before ITAT - Specified date under DTVSV Act - The High Court observed that Section 2 (1) (a) (ii) of the DTVSV Act includes cases where the time limit for filing an appeal had not expired on the specified date, making the assessee eligible for settlement benefits. - The DTVSV Act is aimed at resolving tax disputes and ensuring timely revenue collection. The specified date is 31.01.2020. The legislative intent, as evident from the Finance Minister’s speech and the Statement of Objects and Reasons, was to bring finality to tax disputes and reduce litigation. Thus, the interpretation of the DTVSV Act should be liberal and purposive, extending its benefits to eligible taxpayers. - The Delhi High Court ruled in favor of the assessee, allowing the application under the DTVSV Act.
Eligibility for settlement under DTVSV Act - Delay in filing appeal - Pending appeal before ITAT - Specified date under DTVSV Act - The High Court observed that Section 2 (1) (a) (ii) of the DTVSV Act includes cases where the time limit for filing an appeal had not expired on the specified date, making the assessee eligible for settlement benefits. - The DTVSV Act is aimed at resolving tax disputes and ensuring timely revenue collection. The specified date is 31.01.2020. The legislative intent, as evident from the Finance Minister’s speech and the Statement of Objects and Reasons, was to bring finality to tax disputes and reduce litigation. Thus, the interpretation of the DTVSV Act should be liberal and purposive, extending its benefits to eligible taxpayers. - The Delhi High Court ruled in favor of the assessee, allowing the application under the DTVSV Act.
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