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...
The Punjab and Haryana High Court addressed the issue of refund of excess Input Tax Credit (ITC) and entitlement to interest on delayed refund. The petitioner's application for refund of excess ITC from 2010-11 to 2013-14 was rejected, directing them to apply from the relevant year. The court held that interest on the refund accrued from the date of the first application (27.11.2020) and should have been paid after sixty days. The subsequent assessment proceedings did not affect the petitioner's right to interest on the accrued amount. The court allowed the petition, directing payment of interest on the refunded amount.
The Punjab and Haryana High Court addressed the issue of refund of excess Input Tax Credit (ITC) and entitlement to interest on delayed refund. The petitioner's application for refund of excess ITC from 2010-11 to 2013-14 was rejected, directing them to apply from the relevant year. The court held that interest on the refund accrued from the date of the first application (27.11.2020) and should have been paid after sixty days. The subsequent assessment proceedings did not affect the petitioner's right to interest on the accrued amount. The court allowed the petition, directing payment of interest on the refunded amount.
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