Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Interest on amounts voluntarily deposited during an investigation and later refunded is payable from the actual payment date until the refund date. The relevant approach treats retention of the investigation deposit as warranting interest throughout that period, irrespective of whether the refund claim itself was sanctioned within three months of filing. Interest was directed at 12% per annum, and the prior rejection of interest on the refunded investigation deposit was overturned.
Interest on amounts voluntarily deposited during an investigation and later refunded is payable from the actual payment date until the refund date. The relevant approach treats retention of the investigation deposit as warranting interest throughout that period, irrespective of whether the refund claim itself was sanctioned within three months of filing. Interest was directed at 12% per annum, and the prior rejection of interest on the refunded investigation deposit was overturned.
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