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...
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
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