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...
Valuation by check-post authorities under Sections 129/130 cannot determine tax liability; such valuation is reserved to the jurisdictional Assessing Authority, and interception/confiscation proceedings at transit check posts must refer valuation disputes to that authority, resulting here in refusal to uphold valuation-based seizures. Non-compliance with Rule 138C's contemporaneous online inspection report (Form A) requirement vitiated the detention/confiscation basis and warranted interlocutory release of goods and detained vehicles. Sampling must be redone: samples drawn in triplicate, sealed and countersigned with petitioners or representatives, with one part forwarded to the jurisdictional Assessing Officer who may proceed with assessment.
Valuation by check-post authorities under Sections 129/130 cannot determine tax liability; such valuation is reserved to the jurisdictional Assessing Authority, and interception/confiscation proceedings at transit check posts must refer valuation disputes to that authority, resulting here in refusal to uphold valuation-based seizures. Non-compliance with Rule 138C's contemporaneous online inspection report (Form A) requirement vitiated the detention/confiscation basis and warranted interlocutory release of goods and detained vehicles. Sampling must be redone: samples drawn in triplicate, sealed and countersigned with petitioners or representatives, with one part forwarded to the jurisdictional Assessing Officer who may proceed with assessment.
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