Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Claim of Interest on Refund u/s 7 of the DTVSV Act, 2020 - The High court determined that the petitioner was entitled to refunds as quantified in the Rectification Order dated 29.01.2021. However, it was held that interest under Section 244-A of the IT Act, 1961, was not permissible in light of the DTVSV Act, 2020's provisions, particularly the explanation to Section 7 which precludes interest on excess amounts refunded under the Act. - The court noted the petitioner's adjustments of refunds from later Assessment Years towards the payable amounts for earlier years were acknowledged. However, the court declined the recognition of interest on these adjustments as per the DTVSV Act, 2020.
Claim of Interest on Refund u/s 7 of the DTVSV Act, 2020 - The High court determined that the petitioner was entitled to refunds as quantified in the Rectification Order dated 29.01.2021. However, it was held that interest under Section 244-A of the IT Act, 1961, was not permissible in light of the DTVSV Act, 2020's provisions, particularly the explanation to Section 7 which precludes interest on excess amounts refunded under the Act. - The court noted the petitioner's adjustments of refunds from later Assessment Years towards the payable amounts for earlier years were acknowledged. However, the court declined the recognition of interest on these adjustments as per the DTVSV Act, 2020.
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