Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.