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...
Court found violation of principles of natural justice as petitioner did not receive notices for proceedings leading to impugned orders. Though e-mail service cannot be ruled out, cancellation of registration could have resulted in petitioner not checking that e-mail ID. Court treated present proceedings as notice, granted three weeks to file response, and remanded matter to adjudicating authority for fresh adjudication after giving proper opportunity to petitioner. Impugned order set aside.
Court found violation of principles of natural justice as petitioner did not receive notices for proceedings leading to impugned orders. Though e-mail service cannot be ruled out, cancellation of registration could have resulted in petitioner not checking that e-mail ID. Court treated present proceedings as notice, granted three weeks to file response, and remanded matter to adjudicating authority for fresh adjudication after giving proper opportunity to petitioner. Impugned order set aside.
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