Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The Supreme Court upheld the dismissal of the refund claim as time barred, affirming that the limitation period commenced from the "date of service" of the finalization of provisional assessment under section 27(1B)(c) of the Customs Act, 1962. The Court concurred with the High Court's finding that the tribunal appropriately considered the documentation notifying the assessee of the finalization. Exercising jurisdiction under Article 136 of the Constitution, the SC found no grounds to interfere with the impugned order. Consequently, the special leave petition was dismissed, finalizing the rejection of the refund claim on limitation grounds.
The Supreme Court upheld the dismissal of the refund claim as time barred, affirming that the limitation period commenced from the "date of service" of the finalization of provisional assessment under section 27(1B)(c) of the Customs Act, 1962. The Court concurred with the High Court's finding that the tribunal appropriately considered the documentation notifying the assessee of the finalization. Exercising jurisdiction under Article 136 of the Constitution, the SC found no grounds to interfere with the impugned order. Consequently, the special leave petition was dismissed, finalizing the rejection of the refund claim on limitation grounds.
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