Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Amounts paid under protest during provisional assessment were treated as revenue deposits, not duty, so Section 11B/11BB did not govern the refund or delay interest. Because the payment never acquired the character of duty and no pre-existing quantified liability existed, interest ran from each date of deposit until actual refund, not three months after the refund claim. The Tribunal also held that the proper rate was 12% per annum, with interest already paid to be adjusted.
Amounts paid under protest during provisional assessment were treated as revenue deposits, not duty, so Section 11B/11BB did not govern the refund or delay interest. Because the payment never acquired the character of duty and no pre-existing quantified liability existed, interest ran from each date of deposit until actual refund, not three months after the refund claim. The Tribunal also held that the proper rate was 12% per annum, with interest already paid to be adjusted.
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