Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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The HC upheld a transfer order under s.127(2) of the Income Tax Act relocating the petitioner's case from Mumbai to New Delhi. The court found substantial compliance with statutory requirements, noting proper consultation and agreement between Principal Commissioners and Chief Commissioners. The transfer was justified on merits to facilitate centralization of cases connected to the Pacific Group, where revenue evasion necessitated consolidated investigation. The court declined to exercise its extraordinary jurisdiction under Article 226, emphasizing that such discretionary power is reserved for promoting justice rather than addressing mere legal technicalities, particularly when jurisdictional parameters have been satisfied. The writ petition was accordingly dismissed.
The HC upheld a transfer order under s.127(2) of the Income Tax Act relocating the petitioner's case from Mumbai to New Delhi. The court found substantial compliance with statutory requirements, noting proper consultation and agreement between Principal Commissioners and Chief Commissioners. The transfer was justified on merits to facilitate centralization of cases connected to the Pacific Group, where revenue evasion necessitated consolidated investigation. The court declined to exercise its extraordinary jurisdiction under Article 226, emphasizing that such discretionary power is reserved for promoting justice rather than addressing mere legal technicalities, particularly when jurisdictional parameters have been satisfied. The writ petition was accordingly dismissed.
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