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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Section 62(2) was applied to hold that an assessment made for non-filing of returns stands automatically withdrawn when the registered person files the returns for the relevant period and pays the tax, interest and late fee. On the petitioner's assertion that these requirements had been met, the assessment order was treated as deemed withdrawn, so recovery steps founded on it, including garnishee proceedings, could not continue. The relief was made subject to verification by the authorities of the date of filing and payment of the dues.
Section 62(2) was applied to hold that an assessment made for non-filing of returns stands automatically withdrawn when the registered person files the returns for the relevant period and pays the tax, interest and late fee. On the petitioner's assertion that these requirements had been met, the assessment order was treated as deemed withdrawn, so recovery steps founded on it, including garnishee proceedings, could not continue. The relief was made subject to verification by the authorities of the date of filing and payment of the dues.
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