Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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