Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
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Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods - import of capital goods from AE - The tribunal overturned the TPO's and CIT(A)'s adjustments and methodologies, reinstating the appellant's method for benchmarking international transactions as compliant with the Income Tax Rules. It emphasized that the project cost approved by regulatory commissions and financed by specialized institutions validated the appellant's expenditure on imported capital goods.
Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods - import of capital goods from AE - The tribunal overturned the TPO's and CIT(A)'s adjustments and methodologies, reinstating the appellant's method for benchmarking international transactions as compliant with the Income Tax Rules. It emphasized that the project cost approved by regulatory commissions and financed by specialized institutions validated the appellant's expenditure on imported capital goods.
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