Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Interest on refundable revenue deposits, including unspent Personal Ledger Account balances, is payable from the date of deposit where amounts were deposited during investigation before any duty liability was determined and therefore retained the character of revenue deposits. The majority view rejected the Revenue's challenge to interest from the deposit date and dismissed both appeals. The discussion distinguishes statutory and equitable interest and rejects blanket awards of 12% interest based solely on Sandvik, requiring consideration of relevant factors and later Supreme Court guidance. The majority treated the jurisdictional High Court ruling in Parle Agro as governing the entitlement to interest from the deposit date.
Interest on refundable revenue deposits, including unspent Personal Ledger Account balances, is payable from the date of deposit where amounts were deposited during investigation before any duty liability was determined and therefore retained the character of revenue deposits. The majority view rejected the Revenue's challenge to interest from the deposit date and dismissed both appeals. The discussion distinguishes statutory and equitable interest and rejects blanket awards of 12% interest based solely on Sandvik, requiring consideration of relevant factors and later Supreme Court guidance. The majority treated the jurisdictional High Court ruling in Parle Agro as governing the entitlement to interest from the deposit date.
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