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 interest on delayed refund - The Parliament has enacted this law to ensure that the refunds should carry interest. It would imply that any money belonging to the petitioner, which is with the possession of the respondents, requires to be returned along with the rate of interest mentioned therein. Therefore, whether it is a refund of claim of tax or payment in terms of the order of the Tribunal, the petitioner should be entitled for the interest. - HC
Claim of interest on delayed refund - The Parliament has enacted this law to ensure that the refunds should carry interest. It would imply that any money belonging to the petitioner, which is with the possession of the respondents, requires to be returned along with the rate of interest mentioned therein. Therefore, whether it is a refund of claim of tax or payment in terms of the order of the Tribunal, the petitioner should be entitled for the interest. - HC
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