Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The HC allowed the petition and directed Respondent Nos. 2 and 3 to pay interest on the delayed refund to the petitioner, holding that technical system defects, not any fault of the petitioner in filing the shipping bills or GST returns, caused the delay. The court found section 56 of the GST Act mandates compensatory interest where a refund is not granted within the statutory period under section 54(5), and therefore interest accrues from the relevant statutory date. The respondents were ordered to compute and disburse the interest in accordance with law within 12 weeks from receipt of the order, and the petition was allowed.
The HC allowed the petition and directed Respondent Nos. 2 and 3 to pay interest on the delayed refund to the petitioner, holding that technical system defects, not any fault of the petitioner in filing the shipping bills or GST returns, caused the delay. The court found section 56 of the GST Act mandates compensatory interest where a refund is not granted within the statutory period under section 54(5), and therefore interest accrues from the relevant statutory date. The respondents were ordered to compute and disburse the interest in accordance with law within 12 weeks from receipt of the order, and the petition was allowed.
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