Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Interest on delayed refund - relevant time for calculation of interest - Considering Section 30 of the Act, which stipulates interest on delayed refunds, the court examined both parties' submissions. The court held that the petitioner had made the refund claim within the stipulated time frame, and there was no evidence of delay attributable to them. Therefore, the petitioner was entitled to interest on the delayed refund.
Interest on delayed refund - relevant time for calculation of interest - Considering Section 30 of the Act, which stipulates interest on delayed refunds, the court examined both parties' submissions. The court held that the petitioner had made the refund claim within the stipulated time frame, and there was no evidence of delay attributable to them. Therefore, the petitioner was entitled to interest on the delayed refund.
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