Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Claim of Interest on Refund of pre-deposit - Rejection on the ground that the amount of interest on the refund claim as was already sanctioned to the appellant - The Appellate Tribunal holds that the appellant is entitled to interest on the refund of the pre-deposit amount. It cites various legal precedents and interpretations to support this decision. The Tribunal rejects the department's argument and affirms the appellant's entitlement to interest at a rate of 12% per annum from the date of deposit to the date of payment. - It dismisses the department's reliance on a notification from 2014 and determines the interest rate based on legal precedents and the specific circumstances of the case.
Claim of Interest on Refund of pre-deposit - Rejection on the ground that the amount of interest on the refund claim as was already sanctioned to the appellant - The Appellate Tribunal holds that the appellant is entitled to interest on the refund of the pre-deposit amount. It cites various legal precedents and interpretations to support this decision. The Tribunal rejects the department's argument and affirms the appellant's entitlement to interest at a rate of 12% per annum from the date of deposit to the date of payment. - It dismisses the department's reliance on a notification from 2014 and determines the interest rate based on legal precedents and the specific circumstances of the case.
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