Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Transfer of assessment jurisdiction under Section 127 was challenged on the ground that the case should instead proceed at the original station and that incriminating material, if any, ought to have been routed there. The court held that Section 127 is a machinery provision enabling transfer for administrative convenience, coordinated investigation, efficient tax collection, and public interest, subject to prior reasonable opportunity and recorded reasons. As no mala fides were alleged, adequate hearing was granted, and the impugned order was a speaking order with acceptable reasons, the transfer was upheld and writ interference was declined. It was further held that Section 158BD does not bar centralization where linked entities are assessed elsewhere, if Section 127 procedure is followed. - HC
Transfer of assessment jurisdiction under Section 127 was challenged on the ground that the case should instead proceed at the original station and that incriminating material, if any, ought to have been routed there. The court held that Section 127 is a machinery provision enabling transfer for administrative convenience, coordinated investigation, efficient tax collection, and public interest, subject to prior reasonable opportunity and recorded reasons. As no mala fides were alleged, adequate hearing was granted, and the impugned order was a speaking order with acceptable reasons, the transfer was upheld and writ interference was declined. It was further held that Section 158BD does not bar centralization where linked entities are assessed elsewhere, if Section 127 procedure is followed. - HC
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