Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Curative and clarificatory amendment to the Rule 89(5) refund formula applies retrospectively to refund or rectification applications filed within the statutory period, including differential claims for pre-amendment periods under an inverted duty structure. An administrative circular treating the amendment as prospective cannot override the statutory refund entitlement. Supplementary refund claims are maintainable despite earlier adjudication of refunds for the same tax periods, provided the differential amount is otherwise admissible and claimed within the prescribed period. Eligible differential refunds remain subject to arithmetical verification.
Curative and clarificatory amendment to the Rule 89(5) refund formula applies retrospectively to refund or rectification applications filed within the statutory period, including differential claims for pre-amendment periods under an inverted duty structure. An administrative circular treating the amendment as prospective cannot override the statutory refund entitlement. Supplementary refund claims are maintainable despite earlier adjudication of refunds for the same tax periods, provided the differential amount is otherwise admissible and claimed within the prescribed period. Eligible differential refunds remain subject to arithmetical verification.
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