Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Return filed in response to a reassessment notice may be treated as a regular return where delayed filing was bona fide because an advance-ruling application on the taxability of the sole transaction remained pending. Credit of tax deducted at source and other prepaid taxes must be allowed against the assessed demand; once such adjustment is permissible, excess prepaid tax cannot be denied as a refund without statutory basis. Fresh assessment must verify the prepaid-tax credits, grant any resulting refund with applicable interest, and may entail fresh penalty proceedings where warranted.
Return filed in response to a reassessment notice may be treated as a regular return where delayed filing was bona fide because an advance-ruling application on the taxability of the sole transaction remained pending. Credit of tax deducted at source and other prepaid taxes must be allowed against the assessed demand; once such adjustment is permissible, excess prepaid tax cannot be denied as a refund without statutory basis. Fresh assessment must verify the prepaid-tax credits, grant any resulting refund with applicable interest, and may entail fresh penalty proceedings where warranted.
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