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...
The HC allowed the writ petitions by quashing the impugned assessment orders and remitting the matters to the respondents for fresh adjudication on merits. The court noted the petitioners' failure to respond to preceding show-cause notices and considered the applicability of notifications issued under Section 168A. In view of a recent decision of the Principal Bench invalidating the impugned Section 168A notification with consequential directions, the HC set aside the assessments without deciding substantive tax liability and directed the respondents to proceed afresh, observing that consequential statutory and procedural safeguards be afforded on reconsideration. The writ petitions are disposed of accordingly.
The HC allowed the writ petitions by quashing the impugned assessment orders and remitting the matters to the respondents for fresh adjudication on merits. The court noted the petitioners' failure to respond to preceding show-cause notices and considered the applicability of notifications issued under Section 168A. In view of a recent decision of the Principal Bench invalidating the impugned Section 168A notification with consequential directions, the HC set aside the assessments without deciding substantive tax liability and directed the respondents to proceed afresh, observing that consequential statutory and procedural safeguards be afforded on reconsideration. The writ petitions are disposed of accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
