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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The HC held that the revenue/department cannot withhold a sanctioned refund based solely on its opinion under Section 54(11) of the Act; where the Appellate Authority has permitted the refund and there is no appeal or stay or other proceeding challenging that order, the departmental opinion does not justify retention of the refund. Accordingly, the Appellate Authority's order permitting refund must be given effect to and the refund is to be released to the Petitioner. The petition is disposed of with directions consistent with the Appellate Authority's order.
The HC held that the revenue/department cannot withhold a sanctioned refund based solely on its opinion under Section 54(11) of the Act; where the Appellate Authority has permitted the refund and there is no appeal or stay or other proceeding challenging that order, the departmental opinion does not justify retention of the refund. Accordingly, the Appellate Authority's order permitting refund must be given effect to and the refund is to be released to the Petitioner. The petition is disposed of with directions consistent with the Appellate Authority's order.
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