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...
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
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