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...
Court set aside auction sale on equitable grounds as entire amount due was deposited by respondents. Appellant deprived of using Rs.81,20,000 from 21.07.2019 till refund, entitled to interest at 6% per annum on said amount from deposit date till refund date. Auction conducted by respondent at bank's instance, hence bank liable to pay interest. Impugned judgments modified to direct bank to pay simple interest at 6% per annum on Rs.81,20,000 to appellant from 21.07.2019 till actual refund date instead of 5% solatium. Appeal partly allowed.
Court set aside auction sale on equitable grounds as entire amount due was deposited by respondents. Appellant deprived of using Rs.81,20,000 from 21.07.2019 till refund, entitled to interest at 6% per annum on said amount from deposit date till refund date. Auction conducted by respondent at bank's instance, hence bank liable to pay interest. Impugned judgments modified to direct bank to pay simple interest at 6% per annum on Rs.81,20,000 to appellant from 21.07.2019 till actual refund date instead of 5% solatium. Appeal partly allowed.
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