Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Interest on belated payment of self-assessed tax was held recoverable as a statutory consequence under section 50(1) where the tax was paid only after departmental pointing-out. Sections 73 and 74, read with section 75(12) and section 79, were treated as a complete code for the relevant recovery mechanism, and unpaid interest remained recoverable notwithstanding those provisions. The explanation to section 75(12) was read broadly enough to cover tax payable on outward supplies not included in the return, so the recovery proceedings were sustainable. Mere reference to section 74 in the summary forms did not invalidate them, though the matter was remitted for reconsideration of the reply and a fresh order.
Interest on belated payment of self-assessed tax was held recoverable as a statutory consequence under section 50(1) where the tax was paid only after departmental pointing-out. Sections 73 and 74, read with section 75(12) and section 79, were treated as a complete code for the relevant recovery mechanism, and unpaid interest remained recoverable notwithstanding those provisions. The explanation to section 75(12) was read broadly enough to cover tax payable on outward supplies not included in the return, so the recovery proceedings were sustainable. Mere reference to section 74 in the summary forms did not invalidate them, though the matter was remitted for reconsideration of the reply and a fresh order.
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