Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The dominant issue was whether the refund application was time-barred. Relying on its earlier ruling in an identical factual matrix, the Court held that rejection of the refund solely on limitation was contrary to facts and law because the refund claim had been filed within the prescribed time. Consequently, the impugned rejection order was set aside and the matter was remitted to the adjudicating authority for fresh consideration in accordance with law, and the writ petition was allowed. - HC
The dominant issue was whether the refund application was time-barred. Relying on its earlier ruling in an identical factual matrix, the Court held that rejection of the refund solely on limitation was contrary to facts and law because the refund claim had been filed within the prescribed time. Consequently, the impugned rejection order was set aside and the matter was remitted to the adjudicating authority for fresh consideration in accordance with law, and the writ petition was allowed. - HC
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