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...
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A first appellate order that merely reproduces the parties' submissions and the Assessing Officer's findings, and then reverses the assessment in a few lines by relying on another case, is inadequate because reasons are essential for appellate scrutiny and for showing application of mind to facts and law. Where the CIT(A) does not give effective adjudication, remand for fresh decision is appropriate; the Tribunal need not substitute itself as the primary appellate forum simply because it is the last fact-finding authority. Reliance on Arvind Kumar Jaiswal was found inapposite on these facts, and the remand to the CIT(A) was upheld.
A first appellate order that merely reproduces the parties' submissions and the Assessing Officer's findings, and then reverses the assessment in a few lines by relying on another case, is inadequate because reasons are essential for appellate scrutiny and for showing application of mind to facts and law. Where the CIT(A) does not give effective adjudication, remand for fresh decision is appropriate; the Tribunal need not substitute itself as the primary appellate forum simply because it is the last fact-finding authority. Reliance on Arvind Kumar Jaiswal was found inapposite on these facts, and the remand to the CIT(A) was upheld.
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