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 High Court addressed the violation of principles of natural justice. The impugned order of assessment was not properly served on the petitioner, as it was merely uploaded on the common portal instead of being tendered or sent via RPAD. Consequently, the impugned order was set aside. The petitioner was directed to deposit 25% of the disputed tax within two weeks from receiving the order's copy. Upon complying, the impugned assessment order shall be treated as a show cause notice. The petitioner must submit objections within four weeks from receiving the order's copy, along with supporting documents. If objections are filed, the respondent shall consider them and pass orders in accordance with law after affording a reasonable opportunity of hearing to the petitioner.
The High Court addressed the violation of principles of natural justice. The impugned order of assessment was not properly served on the petitioner, as it was merely uploaded on the common portal instead of being tendered or sent via RPAD. Consequently, the impugned order was set aside. The petitioner was directed to deposit 25% of the disputed tax within two weeks from receiving the order's copy. Upon complying, the impugned assessment order shall be treated as a show cause notice. The petitioner must submit objections within four weeks from receiving the order's copy, along with supporting documents. If objections are filed, the respondent shall consider them and pass orders in accordance with law after affording a reasonable opportunity of hearing to the petitioner.
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