Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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