Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Where an income-tax refund is due and adjustment against an outstanding demand is proposed under section 245 of the Income-tax Act, 1961, the tax department may retain only the amount proposed for adjustment or withholding. It must promptly release the balance refund, without prejudicing either party's right to challenge the legality of the outstanding demand or the proposed adjustment. The balance refund was directed to be credited within the stipulated period; failure to do so would attract interest at the rate directed by the High Court.
Where an income-tax refund is due and adjustment against an outstanding demand is proposed under section 245 of the Income-tax Act, 1961, the tax department may retain only the amount proposed for adjustment or withholding. It must promptly release the balance refund, without prejudicing either party's right to challenge the legality of the outstanding demand or the proposed adjustment. The balance refund was directed to be credited within the stipulated period; failure to do so would attract interest at the rate directed by the High Court.
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