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...
Invocation of the extended limitation period under Section 73(1) of the Finance Act, 1994 was held unsustainable because the show-cause notice did not plead or disclose the requisite jurisdictional ingredients (such as suppression or wilful misstatement) and lacked supporting material. Limitation was treated as a jurisdictional fact, requiring satisfaction of both factual and legal elements before extended limitation could be assumed. Since the notice was cryptic, non-speaking, and unreasoned, the authority could not lawfully assume jurisdiction by invoking Section 73(1). Consequently, the show-cause notice and all proceedings pursuant to it were quashed, and the petition was allowed. - HC
Invocation of the extended limitation period under Section 73(1) of the Finance Act, 1994 was held unsustainable because the show-cause notice did not plead or disclose the requisite jurisdictional ingredients (such as suppression or wilful misstatement) and lacked supporting material. Limitation was treated as a jurisdictional fact, requiring satisfaction of both factual and legal elements before extended limitation could be assumed. Since the notice was cryptic, non-speaking, and unreasoned, the authority could not lawfully assume jurisdiction by invoking Section 73(1). Consequently, the show-cause notice and all proceedings pursuant to it were quashed, and the petition was allowed. - HC
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