Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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