Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The case involves interest on a refund claim u/s 11BB of the Central Excise Act, 1944. The issue was whether interest should be calculated from three months after the Tribunal's final order or from the date of the order. The appellant was found entitled to interest u/s 11BB. The Supreme Court clarified that certain refunds are not covered by Section 11B or 35FF, so the denial of interest was unjustified. The appellant was entitled to interest from the date of deposit till refund at a rate of 12% per annum due to the denial of a benefit. The appeal was allowed, setting aside the previous findings.
The case involves interest on a refund claim u/s 11BB of the Central Excise Act, 1944. The issue was whether interest should be calculated from three months after the Tribunal's final order or from the date of the order. The appellant was found entitled to interest u/s 11BB. The Supreme Court clarified that certain refunds are not covered by Section 11B or 35FF, so the denial of interest was unjustified. The appellant was entitled to interest from the date of deposit till refund at a rate of 12% per annum due to the denial of a benefit. The appeal was allowed, setting aside the previous findings.
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