Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Refund of excess tax paid - rejection on the ground of time limitation - only under specific circumstances like “unconstitutionality, illegal levy, mistake of law’’ etc., a person can take recourse to writ jurisdiction or Contracts Act etc., where the limitation under Section 11B would not be applicable - thus, the refund in this case would squarely be covered by Section 11B as made applicable by Section 83 of Finance Act and therefore if the refund was not filed within the time period prescribed from the relevant date, the refund itself becomes non maintenable irrespective of the merit of the case. - AT
Refund of excess tax paid - rejection on the ground of time limitation - only under specific circumstances like “unconstitutionality, illegal levy, mistake of law’’ etc., a person can take recourse to writ jurisdiction or Contracts Act etc., where the limitation under Section 11B would not be applicable - thus, the refund in this case would squarely be covered by Section 11B as made applicable by Section 83 of Finance Act and therefore if the refund was not filed within the time period prescribed from the relevant date, the refund itself becomes non maintenable irrespective of the merit of the case. - AT
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