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...
HC allowed petition - Assessing officer's order violated principles of natural justice by denying opportunity to petitioner to present defense - Failure to serve show cause notice rendered proceedings flawed - Appeal remedy denied due to delay caused by lack of knowledge of order - Procedural requirements mandatory, non-compliance invalidates actions - Fair opportunity must be given to all parties - Appeal timelines to consider actual knowledge of orders - Assessing officer's order treated as show cause notice to enable petitioner to file objections.
HC allowed petition - Assessing officer's order violated principles of natural justice by denying opportunity to petitioner to present defense - Failure to serve show cause notice rendered proceedings flawed - Appeal remedy denied due to delay caused by lack of knowledge of order - Procedural requirements mandatory, non-compliance invalidates actions - Fair opportunity must be given to all parties - Appeal timelines to consider actual knowledge of orders - Assessing officer's order treated as show cause notice to enable petitioner to file objections.
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