Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
TDS credit transferred following amalgamation must be granted to the amalgamated entity where the related income is substantively assessed in its hands and the amalgamating entity has not claimed that credit. Section 199 read with Rule 37BA applies despite the TDS appearing under the amalgamating entity's PAN. Where the credit was claimed in the original and revised returns and subsequently allowed, refund interest under section 244A(1) is payable for the full applicable period. Delay cannot be excluded under section 244A(2) merely because the Assessing Officer wrongly attributes default to the taxpayer.
TDS credit transferred following amalgamation must be granted to the amalgamated entity where the related income is substantively assessed in its hands and the amalgamating entity has not claimed that credit. Section 199 read with Rule 37BA applies despite the TDS appearing under the amalgamating entity's PAN. Where the credit was claimed in the original and revised returns and subsequently allowed, refund interest under section 244A(1) is payable for the full applicable period. Delay cannot be excluded under section 244A(2) merely because the Assessing Officer wrongly attributes default to the taxpayer.
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