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...
Scope of SCN - Refund claim - Unutilised Input Tax Credit (ITC) - applicability of principle of res judicata - Adherence to the Accounting Standards or not - Specific goods have not been capitalised by the Petitioner in accordance with Accounting Standard 10. - The Court found merit in the Company's contention that the tax authorities' approach lacked consistency. It emphasized the importance of uniform treatment for similar factual and legal circumstances, highlighting that the arbitrary withholding of refunds for the disputed periods was unjustified.
Scope of SCN - Refund claim - Unutilised Input Tax Credit (ITC) - applicability of principle of res judicata - Adherence to the Accounting Standards or not - Specific goods have not been capitalised by the Petitioner in accordance with Accounting Standard 10. - The Court found merit in the Company's contention that the tax authorities' approach lacked consistency. It emphasized the importance of uniform treatment for similar factual and legal circumstances, highlighting that the arbitrary withholding of refunds for the disputed periods was unjustified.
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