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...
Refund claim - refund rejected on the ground that the bills of entry under which assessments were made were not assailed - refund of duty is a mechanical process of returning the excess duty paid. The officer sanctioning refund cannot sit in judgment or modify the assessment by the assessing officer. Any modification to the assessment is possible either by an appeal before the Commissioner (Appeals) or by issue of a notice under section 28. It was, therefore, held that no refund can be sanctioned so as to modify the assessment of bill of entry. - AT
Refund claim - refund rejected on the ground that the bills of entry under which assessments were made were not assailed - refund of duty is a mechanical process of returning the excess duty paid. The officer sanctioning refund cannot sit in judgment or modify the assessment by the assessing officer. Any modification to the assessment is possible either by an appeal before the Commissioner (Appeals) or by issue of a notice under section 28. It was, therefore, held that no refund can be sanctioned so as to modify the assessment of bill of entry. - AT
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