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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The HC directed the Revenue to calculate interest under section 244A on the refund granted to the Petitioner for A.Y.2009-10 up to 31 July 2025 and to pay the same within four weeks. For A.Y.2008-09 the Assessing Officer was directed to adjudicate the Petitioner's rectification application expeditiously, in any event within eight weeks, and to determine interest under section 244A up to the date of actual payment when passing the rectification order. The Writ Petition was disposed of in those terms, with the reliefs confined to the interest calculation and rectification directions specified.
The HC directed the Revenue to calculate interest under section 244A on the refund granted to the Petitioner for A.Y.2009-10 up to 31 July 2025 and to pay the same within four weeks. For A.Y.2008-09 the Assessing Officer was directed to adjudicate the Petitioner's rectification application expeditiously, in any event within eight weeks, and to determine interest under section 244A up to the date of actual payment when passing the rectification order. The Writ Petition was disposed of in those terms, with the reliefs confined to the interest calculation and rectification directions specified.
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