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 applicant had suppressed material facts from the Authority for Advance Ruling by mis-declaring that the issue was not pending in any other proceedings, when in fact, proceedings on the same issue had already commenced by the DGGI. Upon being informed of this by the Appellant, the Authority for Advance Ruling declared the Ruling void ab initio u/s 104 of the Act. Consequently, the appeal filed by the Appellant before the Appellate Authority for Advance Ruling against the void Ruling became infructuous and was dismissed.
The applicant had suppressed material facts from the Authority for Advance Ruling by mis-declaring that the issue was not pending in any other proceedings, when in fact, proceedings on the same issue had already commenced by the DGGI. Upon being informed of this by the Appellant, the Authority for Advance Ruling declared the Ruling void ab initio u/s 104 of the Act. Consequently, the appeal filed by the Appellant before the Appellate Authority for Advance Ruling against the void Ruling became infructuous and was dismissed.
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