Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Statutory refund interest is confined to the rate and scope provided by the statute; a claim for 12% interest was rejected because no additional interest beyond the statutory scheme can be awarded. Amounts paid during customs investigation, before assessment or a crystallised liability, remain deposits and do not become duty merely because they are credited under a duty head. Where an appeal is filed after the mandatory pre-deposit, any further amount retained cannot be appropriated as duty; the entire sum deposited during investigation or before appeal is to be treated as pre-deposit and refunded with statutory interest under section 129EE from the date of deposit, with only interest computation left open.
Statutory refund interest is confined to the rate and scope provided by the statute; a claim for 12% interest was rejected because no additional interest beyond the statutory scheme can be awarded. Amounts paid during customs investigation, before assessment or a crystallised liability, remain deposits and do not become duty merely because they are credited under a duty head. Where an appeal is filed after the mandatory pre-deposit, any further amount retained cannot be appropriated as duty; the entire sum deposited during investigation or before appeal is to be treated as pre-deposit and refunded with statutory interest under section 129EE from the date of deposit, with only interest computation left open.
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