Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Interest on a delayed refund accrued automatically once the statutory six-month period expired without payment, and the department could not release only the principal while withholding the interest component. The High Court held that the statutory mandate required interest to be computed from the day after expiry of the six-month period until disposal, and directed payment of the interest within two weeks. It further directed that any further default would attract interest at 18% per annum from 16.02.2026 until actual payment, recoverable from the officer responsible rather than the State exchequer.
Interest on a delayed refund accrued automatically once the statutory six-month period expired without payment, and the department could not release only the principal while withholding the interest component. The High Court held that the statutory mandate required interest to be computed from the day after expiry of the six-month period until disposal, and directed payment of the interest within two weeks. It further directed that any further default would attract interest at 18% per annum from 16.02.2026 until actual payment, recoverable from the officer responsible rather than the State exchequer.
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