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...
Excess self-assessment tax refunded after appellate relief attracts interest as a statutory, non-discretionary consequence where tax ultimately chargeable is lower than tax paid. Refund entitlement arises when tax deducted at source, advance tax, self-assessment tax, or regular-assessment tax exceeds the final annual tax liability following appeal or other proceedings. Where prescribed computation categories do not govern, interest on excess tax runs from the payment date. Unpaid interest on the resulting refund must be determined and paid for the relevant period, including up to the point at which interest had already been granted.
Excess self-assessment tax refunded after appellate relief attracts interest as a statutory, non-discretionary consequence where tax ultimately chargeable is lower than tax paid. Refund entitlement arises when tax deducted at source, advance tax, self-assessment tax, or regular-assessment tax exceeds the final annual tax liability following appeal or other proceedings. Where prescribed computation categories do not govern, interest on excess tax runs from the payment date. Unpaid interest on the resulting refund must be determined and paid for the relevant period, including up to the point at which interest had already been granted.
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