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...
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The HC held that the impugned assessment order violated principles of natural justice and suffered from non-application of mind. Despite the petitioner filing multiple replies on 28.10.2023, 21.11.2023, 29.11.2023, and 18.12.2023 to the Show Cause Notice, the authority failed to consider these submissions or even reference them in the final order. Additionally, no opportunity for personal hearing was provided to the petitioner before passing the order. The Court determined that this constituted a gross violation of natural justice principles and demonstrated failure to properly consider material evidence on record. The petition was accordingly disposed of in favor of the petitioner.
The HC held that the impugned assessment order violated principles of natural justice and suffered from non-application of mind. Despite the petitioner filing multiple replies on 28.10.2023, 21.11.2023, 29.11.2023, and 18.12.2023 to the Show Cause Notice, the authority failed to consider these submissions or even reference them in the final order. Additionally, no opportunity for personal hearing was provided to the petitioner before passing the order. The Court determined that this constituted a gross violation of natural justice principles and demonstrated failure to properly consider material evidence on record. The petition was accordingly disposed of in favor of the petitioner.
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