Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Delay and laches barred interference under Article 226 where the petitioner failed to respond properly to the discrepancy notice and show cause notice, did not furnish invoice details before the statutory authority, and raised supplier certificates only belatedly despite their earlier availability. The High Court found no justifiable basis to reopen an assessment that had already attained finality, particularly in view of the prolonged delay and the petitioner's negligence in the statutory proceedings. The writ petition was dismissed and the assessment order left undisturbed.
Delay and laches barred interference under Article 226 where the petitioner failed to respond properly to the discrepancy notice and show cause notice, did not furnish invoice details before the statutory authority, and raised supplier certificates only belatedly despite their earlier availability. The High Court found no justifiable basis to reopen an assessment that had already attained finality, particularly in view of the prolonged delay and the petitioner's negligence in the statutory proceedings. The writ petition was dismissed and the assessment order left undisturbed.
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