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...
Refund of CENVAT Credit - the credit was reversed under GST Law at the time of filing refund claim. - It is very strange that the learned Commissioner (Appeals) has failed to give any finding on the above relied upon decisions and he has placed reliance on decisions which are not relevant to the facts of the present case. The decisions relied upon by the learned Commissioner in the impugned order does not deal with the subject involved in these cases. - The rejection of the refund under Rule 5 of CCR read with Notification No.27/2012 is not sustainable in law - AT
Refund of CENVAT Credit - the credit was reversed under GST Law at the time of filing refund claim. - It is very strange that the learned Commissioner (Appeals) has failed to give any finding on the above relied upon decisions and he has placed reliance on decisions which are not relevant to the facts of the present case. The decisions relied upon by the learned Commissioner in the impugned order does not deal with the subject involved in these cases. - The rejection of the refund under Rule 5 of CCR read with Notification No.27/2012 is not sustainable in law - AT
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