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 determined appellant's entitlement to statutory interest under Notification No. 25/2003-Cus(N.T.) for delayed refund credit, following precedent set in Ranbaxy Laboratories Ltd. case. While interest was granted as compensatory relief under statutory provisions, additional compensation claim was rejected due to dispute between Resolution Professional and Official Liquidator. Tribunal clarified its limitations as statutory body under Customs Act, 1962, noting inability to grant extra-statutory compensation. Interest payment ordered specifically for delay period in crediting refund amount to appellant's account, with appeal partially allowed. Decision reinforces distinction between statutory interest entitlement and non-statutory compensation claims in customs matters.
CESTAT determined appellant's entitlement to statutory interest under Notification No. 25/2003-Cus(N.T.) for delayed refund credit, following precedent set in Ranbaxy Laboratories Ltd. case. While interest was granted as compensatory relief under statutory provisions, additional compensation claim was rejected due to dispute between Resolution Professional and Official Liquidator. Tribunal clarified its limitations as statutory body under Customs Act, 1962, noting inability to grant extra-statutory compensation. Interest payment ordered specifically for delay period in crediting refund amount to appellant's account, with appeal partially allowed. Decision reinforces distinction between statutory interest entitlement and non-statutory compensation claims in customs matters.
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