Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Interest u/s. 244A - interest on unpaid interest - refund awarded in the rectification order u/s. 154 - The appellant contested the decision of the Commissioner of Income Tax (Appeals), emphasizing their entitlement to interest from April 1, 2017, onwards. Despite initial denial by the Assessing Officer, the Tribunal ruled in favor of the appellant, considering the rectification order and the acceptance of Minimum Alternate Tax (MAT) credit. The Tribunal's decision aligned with the appellant's interpretation of section 244A, leading to the allowance of interest from the start of the assessment year to the date of refund.
Interest u/s. 244A - interest on unpaid interest - refund awarded in the rectification order u/s. 154 - The appellant contested the decision of the Commissioner of Income Tax (Appeals), emphasizing their entitlement to interest from April 1, 2017, onwards. Despite initial denial by the Assessing Officer, the Tribunal ruled in favor of the appellant, considering the rectification order and the acceptance of Minimum Alternate Tax (MAT) credit. The Tribunal's decision aligned with the appellant's interpretation of section 244A, leading to the allowance of interest from the start of the assessment year to the date of refund.
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