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 addressed procedural challenge regarding timing of notice issued before expiry of response period to Form GSTR DRC-01A. While petitioner initially contested DRC-01A validity, scope narrowed to requesting underlying materials from authorities. Court affirmed petitioner's right to request documentation and raise jurisdictional objections in response to DRC-01A. Authorities directed to consider such requests per law, ensuring reasonable hearing opportunity. Notably, court preserved petitioner's right to raise all available defenses while maintaining procedural safeguards. Matter disposed with directive to authorities to process any subsequent requests in accordance with statutory provisions.
HC addressed procedural challenge regarding timing of notice issued before expiry of response period to Form GSTR DRC-01A. While petitioner initially contested DRC-01A validity, scope narrowed to requesting underlying materials from authorities. Court affirmed petitioner's right to request documentation and raise jurisdictional objections in response to DRC-01A. Authorities directed to consider such requests per law, ensuring reasonable hearing opportunity. Notably, court preserved petitioner's right to raise all available defenses while maintaining procedural safeguards. Matter disposed with directive to authorities to process any subsequent requests in accordance with statutory provisions.
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