Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Refunds arising from TDS assessments under section 201 or appellate orders constitute crystallised entitlements payable with statutory interest, without requiring Form 26B. Section 200A, Rule 31A and Form 26B govern CPC processing and adjustment of TDS before assessment and do not apply to post-assessment refunds. Such refunds may be withheld or set off against outstanding demands only through a statutory adjustment order under section 245; demands linked to the taxpayer's PAN or related TANs alone do not justify withholding. The Department was directed to release the refunds with applicable interest, with additional interest for delayed credit.
Refunds arising from TDS assessments under section 201 or appellate orders constitute crystallised entitlements payable with statutory interest, without requiring Form 26B. Section 200A, Rule 31A and Form 26B govern CPC processing and adjustment of TDS before assessment and do not apply to post-assessment refunds. Such refunds may be withheld or set off against outstanding demands only through a statutory adjustment order under section 245; demands linked to the taxpayer's PAN or related TANs alone do not justify withholding. The Department was directed to release the refunds with applicable interest, with additional interest for delayed credit.
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