Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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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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