Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Entitlement of Interest on delayed refund - relevant date for calculation of time - In the present case, refund arises only after passing of order-in-appeal by the Commissioner (Appeals) dropping the demand. Therefore, there is no occasion to give refund prior to the date of order-in-appeal. Considering that the refund was sanctioned within three months from the date of application and the refund arose consequent to order of Commissioner (Appeals), no interest is payable from the date of deposit of the duty during investigation. - AT
Entitlement of Interest on delayed refund - relevant date for calculation of time - In the present case, refund arises only after passing of order-in-appeal by the Commissioner (Appeals) dropping the demand. Therefore, there is no occasion to give refund prior to the date of order-in-appeal. Considering that the refund was sanctioned within three months from the date of application and the refund arose consequent to order of Commissioner (Appeals), no interest is payable from the date of deposit of the duty during investigation. - AT
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