Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Notice u/s 142(1) was issued to petitioner, but respondent failed to state when it was delivered/served, violating principles of natural justice. Impugned order deserves to be set aside adopting justice-oriented approach, granting petitioner opportunity to reply to Section 142 notice. Respondent entitled to claim interest on demand amount if order passed against petitioner after remand due to lapse of four years from impugned order.
Notice u/s 142(1) was issued to petitioner, but respondent failed to state when it was delivered/served, violating principles of natural justice. Impugned order deserves to be set aside adopting justice-oriented approach, granting petitioner opportunity to reply to Section 142 notice. Respondent entitled to claim interest on demand amount if order passed against petitioner after remand due to lapse of four years from impugned order.
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