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...
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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
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