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...
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.
Note: It is a system-generated summary and is for quick reference only.