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...
Statutory interest on a refunded investigation deposit treated as a pre-deposit is confined to the rate prescribed by the governing provision and notification. Where the statute creates the right to interest and fixes the rate, the claimant cannot seek a higher amount on equitable or restitutionary grounds unless the provision or notification itself is challenged. Applying that principle, the Court upheld interest at 6% per annum and rejected the claim for a higher rate, holding that no substantial question of law arose and dismissing the appeal.
Statutory interest on a refunded investigation deposit treated as a pre-deposit is confined to the rate prescribed by the governing provision and notification. Where the statute creates the right to interest and fixes the rate, the claimant cannot seek a higher amount on equitable or restitutionary grounds unless the provision or notification itself is challenged. Applying that principle, the Court upheld interest at 6% per annum and rejected the claim for a higher rate, holding that no substantial question of law arose and dismissing the appeal.
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