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...
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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