Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
