Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC rejected the application for condonation of delay in Form-10B, directing the Petitioner to file a supplementary affidavit within 15 days to CBDT. CBDT must review the additional affidavit on its merits, provide a hearing to both parties, and issue a reasoned order within four months. The court left all parties' contentions open, did not examine the sufficiency of cause, and made the rule absolute without cost orders. The restoration proceedings were deemed non-operative as the petition was already restored.
HC rejected the application for condonation of delay in Form-10B, directing the Petitioner to file a supplementary affidavit within 15 days to CBDT. CBDT must review the additional affidavit on its merits, provide a hearing to both parties, and issue a reasoned order within four months. The court left all parties' contentions open, did not examine the sufficiency of cause, and made the rule absolute without cost orders. The restoration proceedings were deemed non-operative as the petition was already restored.
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