Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
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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The assessment order was prima facie passed within the period of limitation on 30.09.2021, as evidenced by the presumption of validity and the email and physical dispatch to the petitioner. However, the petitioner's explanation dated 29.09.2021 was not considered, and the assessment appeared to be completed hurriedly to avoid limitation. To balance the interests, the High Court set aside the impugned assessment order and remitted the case to the respondents to pass orders on merits within six months, without finding fault on either party regarding the limitation issue.
The assessment order was prima facie passed within the period of limitation on 30.09.2021, as evidenced by the presumption of validity and the email and physical dispatch to the petitioner. However, the petitioner's explanation dated 29.09.2021 was not considered, and the assessment appeared to be completed hurriedly to avoid limitation. To balance the interests, the High Court set aside the impugned assessment order and remitted the case to the respondents to pass orders on merits within six months, without finding fault on either party regarding the limitation issue.
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