Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Appellant filed refund claim which was initially rejected by original authority on grounds of ineligibility for exemption notification. Commissioner (Appeals) remanded matter to verify unjust enrichment after holding appellant eligible for exemption. Original authority determined duty element not passed on. Appellant ineligible for interest from date of original refund claim filing. For periods without show cause notice, refund claims filed later. Appellant eligible for interest on delayed refund payment from date after 3 months of Order-in-Appeal allowing exemption, as per Section 11BB of Central Excise Act.
Appellant filed refund claim which was initially rejected by original authority on grounds of ineligibility for exemption notification. Commissioner (Appeals) remanded matter to verify unjust enrichment after holding appellant eligible for exemption. Original authority determined duty element not passed on. Appellant ineligible for interest from date of original refund claim filing. For periods without show cause notice, refund claims filed later. Appellant eligible for interest on delayed refund payment from date after 3 months of Order-in-Appeal allowing exemption, as per Section 11BB of Central Excise Act.
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