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 HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
The HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
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