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...
A challenge to a show cause notice under the GST framework raises disputed factual issues best resolved in adjudication; accordingly, preadjudication interference is declined. The petitioner need not be compelled to deposit proposed amounts before adjudication. Statements of recipients recorded in investigation may be relied upon by revenue, but the petitioner is entitled to crossexamine those witnesses before any adverse inference is drawn; that right will be afforded. Documentary records relied on by revenue may be challenged for reliability and the petitioner has the right to rebut inferences drawn from such documents. Facts and law must be determined during adjudication.
A challenge to a show cause notice under the GST framework raises disputed factual issues best resolved in adjudication; accordingly, preadjudication interference is declined. The petitioner need not be compelled to deposit proposed amounts before adjudication. Statements of recipients recorded in investigation may be relied upon by revenue, but the petitioner is entitled to crossexamine those witnesses before any adverse inference is drawn; that right will be afforded. Documentary records relied on by revenue may be challenged for reliability and the petitioner has the right to rebut inferences drawn from such documents. Facts and law must be determined during adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
