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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Computation of refund and interest thereon under section 244A - The present case is not a case where interest on interest due was claimed by the assessee. The issue arising in the present case is regarding correct computation of refund. As per the Revenue, while computing the refund and interest thereon under section 244A of the Act, the refund already granted to the assessee should be adjusted against the tax component. However, as per the assessee, the refund already granted to the assessee should be first adjusted against the interest component and balance, if any, towards the tax component of the refund due. - - Decided in favor of assessee - AT
Computation of refund and interest thereon under section 244A - The present case is not a case where interest on interest due was claimed by the assessee. The issue arising in the present case is regarding correct computation of refund. As per the Revenue, while computing the refund and interest thereon under section 244A of the Act, the refund already granted to the assessee should be adjusted against the tax component. However, as per the assessee, the refund already granted to the assessee should be first adjusted against the interest component and balance, if any, towards the tax component of the refund due. - - Decided in favor of assessee - AT
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