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 dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
The HC dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
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