Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
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Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
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