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...
An assessment order cannot be sustained where the authority fixes a personal hearing before the assessee's last available date to file a reply to the show cause notice, because that denies a fair opportunity of hearing; the HC quashed the original order and remitted the matter for fresh hearing and decision. An appellate order rejecting an appeal is equally invalid if it fails to consider a specific condonation of delay ground and give reasons on that request, even where rejection may ultimately be justified; the HC set aside the appellate order for non-consideration of the condonation plea.
An assessment order cannot be sustained where the authority fixes a personal hearing before the assessee's last available date to file a reply to the show cause notice, because that denies a fair opportunity of hearing; the HC quashed the original order and remitted the matter for fresh hearing and decision. An appellate order rejecting an appeal is equally invalid if it fails to consider a specific condonation of delay ground and give reasons on that request, even where rejection may ultimately be justified; the HC set aside the appellate order for non-consideration of the condonation plea.
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