Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Statutory pre-deposit under the erstwhile indirect tax regime is a security furnished as a condition for hearing an appeal, rather than duty. Where first appellate relief sets aside part of a demand and the Department does not challenge that relief, the appellate order becomes final to that extent. Refund of the corresponding pre-deposit cannot be refused merely because the taxpayer intends to challenge the remaining sustained demand. The refund claim attributable to the demand set aside was required to be processed and paid, while no interest claim was pursued.
Statutory pre-deposit under the erstwhile indirect tax regime is a security furnished as a condition for hearing an appeal, rather than duty. Where first appellate relief sets aside part of a demand and the Department does not challenge that relief, the appellate order becomes final to that extent. Refund of the corresponding pre-deposit cannot be refused merely because the taxpayer intends to challenge the remaining sustained demand. The refund claim attributable to the demand set aside was required to be processed and paid, while no interest claim was pursued.
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