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...
Interest on delayed customs-duty refunds is payable where reassessment and refund claims remained pending, with the grant linked to principles of natural justice. Refunds of differential duty deposited during investigation may attract interest at 12 per cent per annum when jurisdictional High Court precedent, following the Sandvik Asia principle, applies. The applicable interest period remains limited to the period already allowed where it was not challenged by the Revenue; the claimant cannot seek to enlarge that period. Interest was accordingly enhanced from 6 per cent to 12 per cent for the unchanged three-month period commencing 30 January 2009 until refund, and the Revenue challenge was rejected.
Interest on delayed customs-duty refunds is payable where reassessment and refund claims remained pending, with the grant linked to principles of natural justice. Refunds of differential duty deposited during investigation may attract interest at 12 per cent per annum when jurisdictional High Court precedent, following the Sandvik Asia principle, applies. The applicable interest period remains limited to the period already allowed where it was not challenged by the Revenue; the claimant cannot seek to enlarge that period. Interest was accordingly enhanced from 6 per cent to 12 per cent for the unchanged three-month period commencing 30 January 2009 until refund, and the Revenue challenge was rejected.
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