Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Wrongful retention of seized Kisan Vikas Patras and Indira Vikas Patras after deposit of the settlement amount justified compensatory interest for loss of opportunity cost, but only from the date the settlement amount was paid until actual release. Because the Settlement Commission's direction to release the instruments after deposit had attained finality, no interest was payable for any earlier period. The amount awarded was treated as restitution for unjustified deprivation, not statutory refund interest, and the Court also allowed further simple interest at 4% per annum on that compensatory amount until payment.
Wrongful retention of seized Kisan Vikas Patras and Indira Vikas Patras after deposit of the settlement amount justified compensatory interest for loss of opportunity cost, but only from the date the settlement amount was paid until actual release. Because the Settlement Commission's direction to release the instruments after deposit had attained finality, no interest was payable for any earlier period. The amount awarded was treated as restitution for unjustified deprivation, not statutory refund interest, and the Court also allowed further simple interest at 4% per annum on that compensatory amount until payment.
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