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 claim - order of assessment in appeal not challenged - The Tribunal acknowledged the appellants' arguments regarding the contractual agreement and the price variation clause but emphasized that the refund claims were filed without challenging the assessment of the Bills of Entry. - Citing the decision in ITC Limited vs. Commissioner, the CESTAT held that refund claims cannot be entertained unless the order of assessment or self-assessment is modified in accordance with the law. It clarified that refund proceedings are not meant for reassessment and that the conditions of exemption cannot be adjudicated within the scope of refund provisions.
Refund claim - order of assessment in appeal not challenged - The Tribunal acknowledged the appellants' arguments regarding the contractual agreement and the price variation clause but emphasized that the refund claims were filed without challenging the assessment of the Bills of Entry. - Citing the decision in ITC Limited vs. Commissioner, the CESTAT held that refund claims cannot be entertained unless the order of assessment or self-assessment is modified in accordance with the law. It clarified that refund proceedings are not meant for reassessment and that the conditions of exemption cannot be adjudicated within the scope of refund provisions.
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