Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The Supreme Court dismissed the Revenue's SLP for delay and on the merits, thereby affirming the High Court's order directing the Revenue to grant interest under section 244A on the refund from the date of TDS deposit until payment, to be completed within 12 weeks. Facts: compensation for acquisition of petitioners' agricultural land attracted interest; assessee's belated return was condoned under section 119(2)(b); tax was deducted under an incorrect provision (section 194C instead of section 194A). The SLP was held to be barred by an unexplained 398-day delay and lacked substantive merit, so the HC relief in favor of the assessee is sustained.
The Supreme Court dismissed the Revenue's SLP for delay and on the merits, thereby affirming the High Court's order directing the Revenue to grant interest under section 244A on the refund from the date of TDS deposit until payment, to be completed within 12 weeks. Facts: compensation for acquisition of petitioners' agricultural land attracted interest; assessee's belated return was condoned under section 119(2)(b); tax was deducted under an incorrect provision (section 194C instead of section 194A). The SLP was held to be barred by an unexplained 398-day delay and lacked substantive merit, so the HC relief in favor of the assessee is sustained.
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