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...
The petitioner contested the levy of interest, claiming tax liability was paid from the credit ledger, precluding interest charges. However, the court observed factual issues requiring detailed scrutiny of records. The petitioner failed to annex the response to the show-cause notice, hindering the court's ability to delve into merits. The statute provides for appellate remedies, with the first appellate authority being functional, albeit the Appellate Tribunal is yet to be constituted. Considering the availability of statutory appellate mechanisms and the need for factual examination, the High Court dismissed the writ petition.
The petitioner contested the levy of interest, claiming tax liability was paid from the credit ledger, precluding interest charges. However, the court observed factual issues requiring detailed scrutiny of records. The petitioner failed to annex the response to the show-cause notice, hindering the court's ability to delve into merits. The statute provides for appellate remedies, with the first appellate authority being functional, albeit the Appellate Tribunal is yet to be constituted. Considering the availability of statutory appellate mechanisms and the need for factual examination, the High Court dismissed the writ petition.
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