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...
Interest on delayed refund must be reckoned from the original refund application date where the earlier refusal to process that application was found illegal and set aside. The later refiled application, prompted only by the authority's unlawful action, cannot be treated as the starting point to defeat interest otherwise payable. The impugned orders were set aside to the extent they denied interest, and the claim was directed to be decided by taking the date of the initial application into account.
Interest on delayed refund must be reckoned from the original refund application date where the earlier refusal to process that application was found illegal and set aside. The later refiled application, prompted only by the authority's unlawful action, cannot be treated as the starting point to defeat interest otherwise payable. The impugned orders were set aside to the extent they denied interest, and the claim was directed to be decided by taking the date of the initial application into account.
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