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...
Service of notice at an incorrect address, despite the taxpayer having informed the authorities of the changed address and the same being reflected in the registration certificate, violated audi alteram partem. The HC found that the show cause notice, adjudication order and appellate order were all served at the old address, and the appellate authority also failed to address the contention of non-receipt of notices and order. The petitioner was therefore denied an effective opportunity to defend the case. On that ground, the impugned proceedings were quashed and the matter was remanded for fresh proceedings in accordance with law.
Service of notice at an incorrect address, despite the taxpayer having informed the authorities of the changed address and the same being reflected in the registration certificate, violated audi alteram partem. The HC found that the show cause notice, adjudication order and appellate order were all served at the old address, and the appellate authority also failed to address the contention of non-receipt of notices and order. The petitioner was therefore denied an effective opportunity to defend the case. On that ground, the impugned proceedings were quashed and the matter was remanded for fresh proceedings in accordance with law.
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