Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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