TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Amounts deposited under protest towards disputed central excise liability retained the character of duty and were refundable only under the statutory scheme in Section 11B; payment under protest merely removed the limitation bar and did not convert the sum into an independent revenue deposit carrying interest from the date of deposit. Interest on delayed refund was governed by Section 11BB and accrued only if refund was not made within three months of receipt of the refund application. Accordingly, interest at 6% was payable only after expiry of three months from the application dated 28.04.2025, and the claim for interest from the original deposit dates was rejected.
Amounts deposited under protest towards disputed central excise liability retained the character of duty and were refundable only under the statutory scheme in Section 11B; payment under protest merely removed the limitation bar and did not convert the sum into an independent revenue deposit carrying interest from the date of deposit. Interest on delayed refund was governed by Section 11BB and accrued only if refund was not made within three months of receipt of the refund application. Accordingly, interest at 6% was payable only after expiry of three months from the application dated 28.04.2025, and the claim for interest from the original deposit dates was rejected.
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