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...
Challenged audit report and show cause notice were ordered reconsideration: the court found Defects 1-6 did not warrant confirmation of demand after verification of records and reconciliations, and observed no established suppression, misstatement or intent to evade tax. The respondent is directed to decide the issues on merits, provide opportunity of hearing and pass fresh orders pursuant to the audit report and show cause notice, preferably within three months of receipt. Interim relief had prevented final orders earlier; writ petitions disposed with remand for fresh consideration.
Challenged audit report and show cause notice were ordered reconsideration: the court found Defects 1-6 did not warrant confirmation of demand after verification of records and reconciliations, and observed no established suppression, misstatement or intent to evade tax. The respondent is directed to decide the issues on merits, provide opportunity of hearing and pass fresh orders pursuant to the audit report and show cause notice, preferably within three months of receipt. Interim relief had prevented final orders earlier; writ petitions disposed with remand for fresh consideration.
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