Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Entitlement to interest on the delayed refund of pre-deposit - Rate of interest - seizure of cash - The court ruled in favor of the appellant, emphasizing that judicial precedents supported a 12% interest rate in the absence of specific statutory provisions at the relevant time. The court rejected the respondents' argument that the interest rate should be 6% based on later notifications, as these were not applicable to the period in question.
Entitlement to interest on the delayed refund of pre-deposit - Rate of interest - seizure of cash - The court ruled in favor of the appellant, emphasizing that judicial precedents supported a 12% interest rate in the absence of specific statutory provisions at the relevant time. The court rejected the respondents' argument that the interest rate should be 6% based on later notifications, as these were not applicable to the period in question.
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