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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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CESTAT dismissed Appellant's claim for interest on refund arising from provisional assessment under Customs Act, 1962. The Tribunal held that interest under Section 27A is payable only when refund is not sanctioned within three months from receipt of complete refund claim and supporting documents. Following Karnataka HC precedent in Commissioner of Customs Mangaluru v JSW Steel Ltd, CESTAT determined that Appellant cannot claim undue advantage from delays caused by incomplete documentation submissions. The proper officer had issued deficiency notice and sanctioned refund within statutory timeframe after receiving Appellant's complete response. CESTAT upheld the impugned order rejecting interest claim, ruling that no delayed refund payment occurred as refund was processed timely per Section 27 requirements once complete documentation was provided.
CESTAT dismissed Appellant's claim for interest on refund arising from provisional assessment under Customs Act, 1962. The Tribunal held that interest under Section 27A is payable only when refund is not sanctioned within three months from receipt of complete refund claim and supporting documents. Following Karnataka HC precedent in Commissioner of Customs Mangaluru v JSW Steel Ltd, CESTAT determined that Appellant cannot claim undue advantage from delays caused by incomplete documentation submissions. The proper officer had issued deficiency notice and sanctioned refund within statutory timeframe after receiving Appellant's complete response. CESTAT upheld the impugned order rejecting interest claim, ruling that no delayed refund payment occurred as refund was processed timely per Section 27 requirements once complete documentation was provided.
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