Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
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Claim of refund of excess interest paid - The payment of excess interest was due to clerical error or due to mistake as to rate of interest applicable, the unjust enrichment is not attracted as the excess payment made is in the nature of deposit. - refund allowed - AT
Claim of refund of excess interest paid - The payment of excess interest was due to clerical error or due to mistake as to rate of interest applicable, the unjust enrichment is not attracted as the excess payment made is in the nature of deposit. - refund allowed - AT
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