Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
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