TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Interest on amounts voluntarily deposited during an investigation and later refunded is payable from the actual payment date until the refund date. The relevant approach treats retention of the investigation deposit as warranting interest throughout that period, irrespective of whether the refund claim itself was sanctioned within three months of filing. Interest was directed at 12% per annum, and the prior rejection of interest on the refunded investigation deposit was overturned.
Interest on amounts voluntarily deposited during an investigation and later refunded is payable from the actual payment date until the refund date. The relevant approach treats retention of the investigation deposit as warranting interest throughout that period, irrespective of whether the refund claim itself was sanctioned within three months of filing. Interest was directed at 12% per annum, and the prior rejection of interest on the refunded investigation deposit was overturned.
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