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...
HC allowed the writ petition, holding that the deficiency memos rejecting the petitioner's refund applications under S.54 CGST Act were legally untenable. The HC found the refund applications complete and accompanied by requisite documents, and ruled that a deficiency memo can be issued only where an application is incomplete or deficient. It further held that amounts deposited in DRC-03 during a search, purportedly under S.74(5), were not voluntary payments and therefore could validly be claimed as refund under S.54. The HC quashed the impugned deficiency memos dated 20.05.2025 and 21.05.2025, and directed the respondents to process the petitioner's refund claims for the DRC-03 payments and pass appropriate orders in accordance with law.
HC allowed the writ petition, holding that the deficiency memos rejecting the petitioner's refund applications under S.54 CGST Act were legally untenable. The HC found the refund applications complete and accompanied by requisite documents, and ruled that a deficiency memo can be issued only where an application is incomplete or deficient. It further held that amounts deposited in DRC-03 during a search, purportedly under S.74(5), were not voluntary payments and therefore could validly be claimed as refund under S.54. The HC quashed the impugned deficiency memos dated 20.05.2025 and 21.05.2025, and directed the respondents to process the petitioner's refund claims for the DRC-03 payments and pass appropriate orders in accordance with law.
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