Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Personal hearing notice issued to petitioner by Assistant Director (SRO) directing appearance before Additional Director (adjudicating authority). Additional Director's jurisdiction enhanced by notification dated 27.09.2018. Case transferred from Special Director to Additional Director due to pecuniary limits. Court held notification prospective, pending cases transferable to appropriate authority. Transfer from Special Director to Additional Director valid as per FEMA provisions for cases between Rs.10-25 crores, petitioner's case involving Rs.11.27 crores. No writ entertainable against show cause notice unless issued by incompetent authority or malafides alleged. Court found transfer valid u/s 16(1), FEMA Act. Writ petitions dismissed.
Personal hearing notice issued to petitioner by Assistant Director (SRO) directing appearance before Additional Director (adjudicating authority). Additional Director's jurisdiction enhanced by notification dated 27.09.2018. Case transferred from Special Director to Additional Director due to pecuniary limits. Court held notification prospective, pending cases transferable to appropriate authority. Transfer from Special Director to Additional Director valid as per FEMA provisions for cases between Rs.10-25 crores, petitioner's case involving Rs.11.27 crores. No writ entertainable against show cause notice unless issued by incompetent authority or malafides alleged. Court found transfer valid u/s 16(1), FEMA Act. Writ petitions dismissed.
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