Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
An amount paid during investigation was treated as a refundable deposit, not a voluntary duty payment, because the assessee had consistently disputed liability and the payment was made under a mistaken impression at the insistence of Revenue. Once the proceedings were dropped, the Tribunal held that refund of the investigation deposit carried interest as a matter of course. Applying its earlier authorities, it further held that interest was payable at 12% from the date of deposit until refund, and the denial of interest was set aside.
An amount paid during investigation was treated as a refundable deposit, not a voluntary duty payment, because the assessee had consistently disputed liability and the payment was made under a mistaken impression at the insistence of Revenue. Once the proceedings were dropped, the Tribunal held that refund of the investigation deposit carried interest as a matter of course. Applying its earlier authorities, it further held that interest was payable at 12% from the date of deposit until refund, and the denial of interest was set aside.
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