Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Refund claim of amount deposited during investigation - the appellant is entitled to refund with interest under Section 35 FF, for which no limitation is applicable. The revenue department cannot retain such amount of Rs. 10 lakhs (in the nature of pre-deposit). Therefore, the original authority is directed to refund Rs. 10 lakhs to the appellant alongwith interest of 12% on the same for the period starting from the date of deposit, till the date of refund. - AT
Refund claim of amount deposited during investigation - the appellant is entitled to refund with interest under Section 35 FF, for which no limitation is applicable. The revenue department cannot retain such amount of Rs. 10 lakhs (in the nature of pre-deposit). Therefore, the original authority is directed to refund Rs. 10 lakhs to the appellant alongwith interest of 12% on the same for the period starting from the date of deposit, till the date of refund. - AT
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