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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The High Court set aside the order u/s 119(2)(b) of the Act, finding that the authority took a restrictive and conservative approach in not noticing the Central Board of Direct Taxes (CBDT) circular dated 09.06.2015 regarding condonation of delay up to six years. The matter was remitted back to the authority to reconsider, taking note of the CBDT circular. The authority must take a holistic view and pass appropriate orders expeditiously, as the period sought to be condoned is within six years, and the restriction on non-condonation applies only beyond six years.
The High Court set aside the order u/s 119(2)(b) of the Act, finding that the authority took a restrictive and conservative approach in not noticing the Central Board of Direct Taxes (CBDT) circular dated 09.06.2015 regarding condonation of delay up to six years. The matter was remitted back to the authority to reconsider, taking note of the CBDT circular. The authority must take a holistic view and pass appropriate orders expeditiously, as the period sought to be condoned is within six years, and the restriction on non-condonation applies only beyond six years.
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