Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Applicability of Circular No.224/18/2024-GST para 6 turns on two preconditions: deposit of the pre-deposit contemplated under Section 112 and provision of an undertaking/intimation to the proper appellate authority. The court accepted that the taxpayer furnished the required intimation and, in the peculiar facts, treated that intimation as sufficient for para 6; accordingly the revenue was directed to refund amounts recovered under the summary demand after withholding the pre-deposit amount as contemplated under Section 112. The taxpayer forewent any claim to interest on the refunded amount.
Applicability of Circular No.224/18/2024-GST para 6 turns on two preconditions: deposit of the pre-deposit contemplated under Section 112 and provision of an undertaking/intimation to the proper appellate authority. The court accepted that the taxpayer furnished the required intimation and, in the peculiar facts, treated that intimation as sufficient for para 6; accordingly the revenue was directed to refund amounts recovered under the summary demand after withholding the pre-deposit amount as contemplated under Section 112. The taxpayer forewent any claim to interest on the refunded amount.
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