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...
Appellate authority failed to consider documentary evidence already placed before the adjudicating authority; accordingly the appellate order is quashed and the matter remanded for fresh hearing requiring consideration of those documents. The petitioner did not appear at the scheduled personal hearings despite service of notices, and the court found absence of fault in the appellate authority's decision to proceed given nonappearance; however the appellate authority was nevertheless obliged to examine the documentary record when adjudicating the appeal, and its failure to do so determined the remand outcome.
Appellate authority failed to consider documentary evidence already placed before the adjudicating authority; accordingly the appellate order is quashed and the matter remanded for fresh hearing requiring consideration of those documents. The petitioner did not appear at the scheduled personal hearings despite service of notices, and the court found absence of fault in the appellate authority's decision to proceed given nonappearance; however the appellate authority was nevertheless obliged to examine the documentary record when adjudicating the appeal, and its failure to do so determined the remand outcome.
Note: It is a system-generated summary and is for quick reference only.