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...
Transfer of Jurisdiction u/s 127 - File were transferred from Kolkata's jurisdiction to Chennai - The Revenue's argument that the PAN and files were still within Kolkata's jurisdiction was dismissed, as the transfer of jurisdiction was a consequential proceeding. The Tribunal's decision was upheld, and the appeal failed against the Revenue.
Transfer of Jurisdiction u/s 127 - File were transferred from Kolkata's jurisdiction to Chennai - The Revenue's argument that the PAN and files were still within Kolkata's jurisdiction was dismissed, as the transfer of jurisdiction was a consequential proceeding. The Tribunal's decision was upheld, and the appeal failed against the Revenue.
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