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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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.
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