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...
Failure to comply with statutory timelines for refund scrutiny means issuance of a deficiency memo after the prescribed period is impermissible, so the refund claim must be processed and allowed in accordance with the applicable acknowledgement and scrutiny rules; the prior direction to sanction refund with statutory interest therefore remains operative and requires enforcement. The writ seeking mandamus for compliance was allowed, directing the respondent to sanction the refund for the specified period together with statutory interest and to complete compliance within the time directed by the Court.
Failure to comply with statutory timelines for refund scrutiny means issuance of a deficiency memo after the prescribed period is impermissible, so the refund claim must be processed and allowed in accordance with the applicable acknowledgement and scrutiny rules; the prior direction to sanction refund with statutory interest therefore remains operative and requires enforcement. The writ seeking mandamus for compliance was allowed, directing the respondent to sanction the refund for the specified period together with statutory interest and to complete compliance within the time directed by the Court.
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