Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.
Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.
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