Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.
Section 132B(4) requires simple interest on refundable seized cash from the day after expiry of 120 days from the last authorisation, and the Revenue cannot defeat that liability by relying on its own failure to complete assessment. Where refund is unduly delayed and no assessment has been made, Article 226 may support compensatory relief beyond the statutory framework. A pending vigilance reference does not justify withholding or postponing interest. The respondents were directed to pay interest on the refunded cash at the statutory rate until refund, with enhanced interest if payment was further delayed.
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TaxTMI 
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