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International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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HC quashed the order of CIT(Appeals) regarding a belated appeal filing, determining that the appeal submitted manually in Form No.35 on 15.06.2016 was valid under Circular No.20/2016. The court found the appeal's dismissal on grounds of delay was improper. The matter was remanded to CIT(Appeals) for a fresh hearing on merits, directing procedural fairness by providing the petitioner an opportunity to present their case in accordance with established legal principles.
HC quashed the order of CIT(Appeals) regarding a belated appeal filing, determining that the appeal submitted manually in Form No.35 on 15.06.2016 was valid under Circular No.20/2016. The court found the appeal's dismissal on grounds of delay was improper. The matter was remanded to CIT(Appeals) for a fresh hearing on merits, directing procedural fairness by providing the petitioner an opportunity to present their case in accordance with established legal principles.
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