Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Interest rate on delayed refunds u/s 11BB of Central Excise Act, 1944 restricted to 6% p.a. as per Notification 67/2003-CE (N.T.), overruling appellant's claim of 12%. Madras and Karnataka High Courts upheld 6% rate, rejecting higher rates claimed. Section 11BB empowers Central Government to fix rate between 5-30% through notification. Notification 67/2003 validly issued fixing 6% rate. Appellant's contention of order being beyond show cause notice unsustainable. Appeal dismissed, affirming impugned orders.
Interest rate on delayed refunds u/s 11BB of Central Excise Act, 1944 restricted to 6% p.a. as per Notification 67/2003-CE (N.T.), overruling appellant's claim of 12%. Madras and Karnataka High Courts upheld 6% rate, rejecting higher rates claimed. Section 11BB empowers Central Government to fix rate between 5-30% through notification. Notification 67/2003 validly issued fixing 6% rate. Appellant's contention of order being beyond show cause notice unsustainable. Appeal dismissed, affirming impugned orders.
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