Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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CESTAT dismissed appeal regarding interest claim on refunded deposits made during investigation. While the deposited amount was initially appropriated by Original Authority as duty against demand, appellant sought interest on refund. Following Mafatlal Industries precedent on jurisdictional scope under Art. 226 and Art. 32, tribunal determined appellant's entitlement to statutory interest under Sec. 11BB of Central Excise Act from deposit date until actual refund date. Despite recognizing interest entitlement, appeal failed on other substantive grounds. Decision upholds legislative framework governing refund interest while respecting constitutional remedies' scope.
CESTAT dismissed appeal regarding interest claim on refunded deposits made during investigation. While the deposited amount was initially appropriated by Original Authority as duty against demand, appellant sought interest on refund. Following Mafatlal Industries precedent on jurisdictional scope under Art. 226 and Art. 32, tribunal determined appellant's entitlement to statutory interest under Sec. 11BB of Central Excise Act from deposit date until actual refund date. Despite recognizing interest entitlement, appeal failed on other substantive grounds. Decision upholds legislative framework governing refund interest while respecting constitutional remedies' scope.
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