Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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