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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
