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...
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
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