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...
Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.
Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.
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