Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Interest on delayed customs refunds of excess duty following reassessment commences after three months from receipt of the refund application, rather than from the later reassessment or refund order. Where the importer pursued reassessment and refund but Revenue delayed action for several years, the delay is attributable to Revenue. Interest was therefore payable from 20.02.2019 until the refund date. The applicable rate was 12 per cent, not 6 per cent, because the refund was withheld through prolonged inaction. The balance interest was required to be paid within eight weeks.
Interest on delayed customs refunds of excess duty following reassessment commences after three months from receipt of the refund application, rather than from the later reassessment or refund order. Where the importer pursued reassessment and refund but Revenue delayed action for several years, the delay is attributable to Revenue. Interest was therefore payable from 20.02.2019 until the refund date. The applicable rate was 12 per cent, not 6 per cent, because the refund was withheld through prolonged inaction. The balance interest was required to be paid within eight weeks.
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