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...
TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.
TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.
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