Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
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Working capital adjustment in a transfer pricing giving-effect order required proper evidentiary substantiation. The Court noted that the earlier direction to reconsider the claim was not enough because the petitioner failed to comply with the later requisition for working capital details and their impact on profit, and had only furnished an Excel calculation of the adjusted margin. Mere calculations were insufficient; the claim had to be authenticated with supporting documents duly certified by a Chartered Accountant. The matter was therefore remitted for fresh consideration on merits, with liberty to upload the required particulars and an opportunity of hearing before a fresh order was passed.
Working capital adjustment in a transfer pricing giving-effect order required proper evidentiary substantiation. The Court noted that the earlier direction to reconsider the claim was not enough because the petitioner failed to comply with the later requisition for working capital details and their impact on profit, and had only furnished an Excel calculation of the adjusted margin. Mere calculations were insufficient; the claim had to be authenticated with supporting documents duly certified by a Chartered Accountant. The matter was therefore remitted for fresh consideration on merits, with liberty to upload the required particulars and an opportunity of hearing before a fresh order was passed.
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