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 respondents improperly sought a 5% compounding charge because such higher rate is chargeable only where an earlier offence has been lawfully compounded and the conditions of that compounding order have been complied with; where the first compounding application was rejected, no compounding order arose and 5% could not be claimed on the subsequent application. The petitioner's contention that the higher rate was inapplicable was accepted, the impugned letter dated 08.02.2019 was set aside, and the respondents were directed to proceed in accordance with law in relation to the pending compounding application and any attendant criminal proceedings.
The HC held that the respondents improperly sought a 5% compounding charge because such higher rate is chargeable only where an earlier offence has been lawfully compounded and the conditions of that compounding order have been complied with; where the first compounding application was rejected, no compounding order arose and 5% could not be claimed on the subsequent application. The petitioner's contention that the higher rate was inapplicable was accepted, the impugned letter dated 08.02.2019 was set aside, and the respondents were directed to proceed in accordance with law in relation to the pending compounding application and any attendant criminal proceedings.
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