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 set aside the impugned demand order and remanded the matter to the Adjudicating Authority for fresh adjudication, finding a breach of audi alteram partem where the SCN and subsequent notices were uploaded only to the "Additional Notices" tab and the Petitioner was not afforded a real opportunity to be heard. The Petitioner is granted time until 15 October 2025 to file a reply to the SCN; thereafter the Adjudicating Authority shall issue a personal hearing notice (not merely portal upload) and proceed afresh. The petition is allowed by way of remand.
The HC set aside the impugned demand order and remanded the matter to the Adjudicating Authority for fresh adjudication, finding a breach of audi alteram partem where the SCN and subsequent notices were uploaded only to the "Additional Notices" tab and the Petitioner was not afforded a real opportunity to be heard. The Petitioner is granted time until 15 October 2025 to file a reply to the SCN; thereafter the Adjudicating Authority shall issue a personal hearing notice (not merely portal upload) and proceed afresh. The petition is allowed by way of remand.
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