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...
The SC dismissed the appeals and disposed of the proceedings in accordance with the Board circular, remitting the matter for recalculation of penalty and refund insofar as a penalty was levied on the entire consignment. The Court held that the impugned order did not fall within the specific category under Clause (iv) of Paragraph 4 of the Circular because the directive concerned recomputation of penalty for a discrete transaction and did not directly require refund or construction of statutory provisions nor did it raise a recurring question of law. Consequently, the appeals were declined and the matter was remanded for reassessment and appropriate refund consistent with the Circular.
The SC dismissed the appeals and disposed of the proceedings in accordance with the Board circular, remitting the matter for recalculation of penalty and refund insofar as a penalty was levied on the entire consignment. The Court held that the impugned order did not fall within the specific category under Clause (iv) of Paragraph 4 of the Circular because the directive concerned recomputation of penalty for a discrete transaction and did not directly require refund or construction of statutory provisions nor did it raise a recurring question of law. Consequently, the appeals were declined and the matter was remanded for reassessment and appropriate refund consistent with the Circular.
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