Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
A GST refund deficiency memo in Form RFD-03 must identify the precise document defects; a vague statement that supporting papers are incomplete is insufficient because the applicant cannot effectively cure unspecified deficiencies. The memo cannot be used to reject the refund claim without particulars, and if treated as a rejection, that reasoning remains unsustainable. The proper course is to communicate the specific defects, allow rectification within time, and then decide the refund claim afresh by a speaking order.
A GST refund deficiency memo in Form RFD-03 must identify the precise document defects; a vague statement that supporting papers are incomplete is insufficient because the applicant cannot effectively cure unspecified deficiencies. The memo cannot be used to reject the refund claim without particulars, and if treated as a rejection, that reasoning remains unsustainable. The proper course is to communicate the specific defects, allow rectification within time, and then decide the refund claim afresh by a speaking order.
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