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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
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