Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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