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...
The HC dismissed the appeal as time barred due to a 91-day delay in filing. The court held that the appellant/department, alleging lack of diligence by the respondent/assessee, must also adhere to the limitation period for filing appeals. The principle of equal diligence applies to both parties. The statute requires a fresh refund application following rectification of deficiencies. The court modified the Single Bench's direction, ordering the respondent to rectify all noted deficiencies and submit a fresh refund application within two weeks of receiving the order's certified copy. The appeal was therefore dismissed, and the matter was remanded for compliance with these conditions.
The HC dismissed the appeal as time barred due to a 91-day delay in filing. The court held that the appellant/department, alleging lack of diligence by the respondent/assessee, must also adhere to the limitation period for filing appeals. The principle of equal diligence applies to both parties. The statute requires a fresh refund application following rectification of deficiencies. The court modified the Single Bench's direction, ordering the respondent to rectify all noted deficiencies and submit a fresh refund application within two weeks of receiving the order's certified copy. The appeal was therefore dismissed, and the matter was remanded for compliance with these conditions.
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