Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Excess TDS becomes refundable where reassessment proceedings initiated under section 148 accept the return and determine nil taxable income. Under section 237, tax paid in excess of tax properly chargeable must be refunded; no outstanding liability remains after such assessment. The refund is consequential to the reassessment rather than a fresh claim beyond its scope. The principle applies even where reassessment proceedings are dropped or culminate without additional taxable income, and the restriction on reopening concluded matters does not bar this consequential relief. Statutory interest on the excess TDS refund follows in accordance with law.
Excess TDS becomes refundable where reassessment proceedings initiated under section 148 accept the return and determine nil taxable income. Under section 237, tax paid in excess of tax properly chargeable must be refunded; no outstanding liability remains after such assessment. The refund is consequential to the reassessment rather than a fresh claim beyond its scope. The principle applies even where reassessment proceedings are dropped or culminate without additional taxable income, and the restriction on reopening concluded matters does not bar this consequential relief. Statutory interest on the excess TDS refund follows in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
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