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...
Circular No.9 dated 24.05.2019 challenged - authority to delegate power of adjudication by circular contrary to Section 167 requiring notification - assessing authority being inspecting authority leading to conflict of interest. Court held circular traceable to Section 2(91), not Section 167, hence notification unnecessary for authorizing adjudication power. Reliance on Gujarat HC judgment rejecting similar challenge. Adjudication of factual disputes beyond Article 226 writ jurisdiction when alternative remedy available. Writ petition against Circular No.9 and assessment orders for 2017-18 to 2020-21 rejected. Petition disposed of.
Circular No.9 dated 24.05.2019 challenged - authority to delegate power of adjudication by circular contrary to Section 167 requiring notification - assessing authority being inspecting authority leading to conflict of interest. Court held circular traceable to Section 2(91), not Section 167, hence notification unnecessary for authorizing adjudication power. Reliance on Gujarat HC judgment rejecting similar challenge. Adjudication of factual disputes beyond Article 226 writ jurisdiction when alternative remedy available. Writ petition against Circular No.9 and assessment orders for 2017-18 to 2020-21 rejected. Petition disposed of.
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