Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
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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