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...
Re-quantification of interest (on the refund of the pre-deposit) payment to the appellant - relevant time - The Tribunal focused on the applicable legal provisions, specifically Section 35FF of the Central Excise Act, 1944, as amended. It noted that the pre-deposit was made before the amendment of this section, and therefore, the provisions applicable at the time of the deposit govern the interest calculations. The Tribunal upheld the view that interest is payable only after three months from the date of the appellate order, as per the unamended Section 35FF.
Re-quantification of interest (on the refund of the pre-deposit) payment to the appellant - relevant time - The Tribunal focused on the applicable legal provisions, specifically Section 35FF of the Central Excise Act, 1944, as amended. It noted that the pre-deposit was made before the amendment of this section, and therefore, the provisions applicable at the time of the deposit govern the interest calculations. The Tribunal upheld the view that interest is payable only after three months from the date of the appellate order, as per the unamended Section 35FF.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
