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 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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