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 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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
