Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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HC ruled that the Petitioner is entitled to interest on refund claim, with nuanced calculations. Interest shall be payable from 7th/9th September, 2019 till 9th June, 2023 at varying rates (6% initially, then 9%), with a deduction of 74 days corresponding to Petitioner's response time to deficiency memo. The court balanced the procedural delays by both tax authority and Petitioner, ultimately granting partial interest relief while accounting for respective timeline contributions. Petition disposed of with specific interest computation guidelines.
HC ruled that the Petitioner is entitled to interest on refund claim, with nuanced calculations. Interest shall be payable from 7th/9th September, 2019 till 9th June, 2023 at varying rates (6% initially, then 9%), with a deduction of 74 days corresponding to Petitioner's response time to deficiency memo. The court balanced the procedural delays by both tax authority and Petitioner, ultimately granting partial interest relief while accounting for respective timeline contributions. Petition disposed of with specific interest computation guidelines.
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