Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
