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...
HC allowed the petition challenging Rule 86A blocking of Electronic Credit Ledger (ECL), finding the order invalid due to lack of pre-decisional hearing and absence of independent, cogent reasons. The court held that reliance on borrowed satisfaction from enforcement reports without providing specific grounds constitutes an arbitrary action. Respondents were directed to immediately unblock the petitioner's ECL, enabling the petitioner to file returns, thus upholding principles of natural justice and procedural fairness in tax administration.
HC allowed the petition challenging Rule 86A blocking of Electronic Credit Ledger (ECL), finding the order invalid due to lack of pre-decisional hearing and absence of independent, cogent reasons. The court held that reliance on borrowed satisfaction from enforcement reports without providing specific grounds constitutes an arbitrary action. Respondents were directed to immediately unblock the petitioner's ECL, enabling the petitioner to file returns, thus upholding principles of natural justice and procedural fairness in tax administration.
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