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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Curative and clarificatory amendment to the Rule 89(5) refund formula applies retrospectively to refund or rectification applications filed within the statutory period, including differential claims for pre-amendment periods under an inverted duty structure. An administrative circular treating the amendment as prospective cannot override the statutory refund entitlement. Supplementary refund claims are maintainable despite earlier adjudication of refunds for the same tax periods, provided the differential amount is otherwise admissible and claimed within the prescribed period. Eligible differential refunds remain subject to arithmetical verification.
Curative and clarificatory amendment to the Rule 89(5) refund formula applies retrospectively to refund or rectification applications filed within the statutory period, including differential claims for pre-amendment periods under an inverted duty structure. An administrative circular treating the amendment as prospective cannot override the statutory refund entitlement. Supplementary refund claims are maintainable despite earlier adjudication of refunds for the same tax periods, provided the differential amount is otherwise admissible and claimed within the prescribed period. Eligible differential refunds remain subject to arithmetical verification.
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