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...
Where recovery of a disputed demand was stayed under section 220(6), the High Court held that the Department could not adjust a later-year refund against that stayed demand. The adjustment was treated as illegal, arbitrary and perfunctory because the stay remained operative until disposal of the first appeal. The Court exercised writ jurisdiction to interfere and directed release of the refund computed under the intimation for the later assessment year, together with statutory interest under section 244A, within the time fixed by the Court.
Where recovery of a disputed demand was stayed under section 220(6), the High Court held that the Department could not adjust a later-year refund against that stayed demand. The adjustment was treated as illegal, arbitrary and perfunctory because the stay remained operative until disposal of the first appeal. The Court exercised writ jurisdiction to interfere and directed release of the refund computed under the intimation for the later assessment year, together with statutory interest under section 244A, within the time fixed by the Court.
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