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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Petitioner failed to establish non-payment of tax demanded was beyond their control. CC reasonably exercised powers u/s 220(2A) after considering relevant circumstances and material on record. Factual findings supported by evidence, no perversity. Chander Prakash Jain case distinguishable on facts, not involving Section 220(2A). HC does not exercise appellate jurisdiction. All three preconditions for waiver u/s 220(2A) not met. Petition dismissed.
Petitioner failed to establish non-payment of tax demanded was beyond their control. CC reasonably exercised powers u/s 220(2A) after considering relevant circumstances and material on record. Factual findings supported by evidence, no perversity. Chander Prakash Jain case distinguishable on facts, not involving Section 220(2A). HC does not exercise appellate jurisdiction. All three preconditions for waiver u/s 220(2A) not met. Petition dismissed.
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