Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Interest on Delayed Refund - The High court carefully considered the submissions of both parties and found merit in the petitioner's contention regarding their statutory entitlement to interest under Section 27A of the Customs Act. The court noted that even if the petitioner had not explicitly requested interest, it would still be their statutory right to claim it upon allowance of the refund applications. - Consequently, the court directed the Adjudicating Officer to determine the petitioner's interest claim, allowing them a hearing to present relevant documents.
Interest on Delayed Refund - The High court carefully considered the submissions of both parties and found merit in the petitioner's contention regarding their statutory entitlement to interest under Section 27A of the Customs Act. The court noted that even if the petitioner had not explicitly requested interest, it would still be their statutory right to claim it upon allowance of the refund applications. - Consequently, the court directed the Adjudicating Officer to determine the petitioner's interest claim, allowing them a hearing to present relevant documents.
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