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...
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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