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...
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Note: It is a system-generated summary and is for quick reference only.