Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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