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...
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HC dismissed the petition challenging the tax assessment, holding that the petitioner failed to demonstrate extraordinary circumstances warranting judicial review under Article 226. The court emphasized that statutory alternative remedies must be exhausted before invoking extraordinary writ jurisdiction. Despite claiming no efficacious alternative remedy, the petitioner did not establish exceptional grounds to bypass prescribed statutory procedures. The determination by the tax authority was found to be based on available record, and the assessment order was not deemed fundamentally flawed to warrant direct HC intervention.
HC dismissed the petition challenging the tax assessment, holding that the petitioner failed to demonstrate extraordinary circumstances warranting judicial review under Article 226. The court emphasized that statutory alternative remedies must be exhausted before invoking extraordinary writ jurisdiction. Despite claiming no efficacious alternative remedy, the petitioner did not establish exceptional grounds to bypass prescribed statutory procedures. The determination by the tax authority was found to be based on available record, and the assessment order was not deemed fundamentally flawed to warrant direct HC intervention.
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