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...
Petitioner challenged appellate orders rejecting refund applications. HC held there are no grounds to invoke extraordinary jurisdiction under Article 226 as statutory appeal lies before Tribunal. Though Tribunal is not constituted, Central Government permitted filing appeal after its constitution. Since impugned orders relate to refund with no demand, pre-deposit of 20% tax demand is not required. Petition closed.
Petitioner challenged appellate orders rejecting refund applications. HC held there are no grounds to invoke extraordinary jurisdiction under Article 226 as statutory appeal lies before Tribunal. Though Tribunal is not constituted, Central Government permitted filing appeal after its constitution. Since impugned orders relate to refund with no demand, pre-deposit of 20% tax demand is not required. Petition closed.
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