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...
ITAT set aside CIT(Appeals)/NFAC's ex parte dismissal of assessee's appeal, holding that the appellate authority lacks power to summarily dismiss an appeal for non-prosecution. The tribunal mandated a de novo adjudication, requiring CIT(Appeals)/NFAC to examine the appeal's merits comprehensively under Section 251 of the Income Tax Act. The order directs the appellate authority to pass a reasoned order within three months, emphasizing the statutory obligation to apply judicial mind to all issues, while cautioning the assessee to comply with future hearing notices.
ITAT set aside CIT(Appeals)/NFAC's ex parte dismissal of assessee's appeal, holding that the appellate authority lacks power to summarily dismiss an appeal for non-prosecution. The tribunal mandated a de novo adjudication, requiring CIT(Appeals)/NFAC to examine the appeal's merits comprehensively under Section 251 of the Income Tax Act. The order directs the appellate authority to pass a reasoned order within three months, emphasizing the statutory obligation to apply judicial mind to all issues, while cautioning the assessee to comply with future hearing notices.
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