Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
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