Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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TDS refunds arising from Section 201 assessments or appellate give-effect orders are crystallised entitlements and cannot be denied or deferred through post-assessment requirements for financial-year-wise particulars or Form 26B. The adjustment framework under Section 200A, Rule 31A and Form 26B operates separately from refunds determined on assessment or under appellate give-effect orders. Refunds also cannot be withheld without a legally passed adjustment order under Section 245. Refundable amounts under the give-effect orders must be processed expeditiously, with applicable statutory interest payable until payment.
TDS refunds arising from Section 201 assessments or appellate give-effect orders are crystallised entitlements and cannot be denied or deferred through post-assessment requirements for financial-year-wise particulars or Form 26B. The adjustment framework under Section 200A, Rule 31A and Form 26B operates separately from refunds determined on assessment or under appellate give-effect orders. Refunds also cannot be withheld without a legally passed adjustment order under Section 245. Refundable amounts under the give-effect orders must be processed expeditiously, with applicable statutory interest payable until payment.
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