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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Interest on refunds of tax paid under a TDS-default demand is governed by Section 244A(1)(b) where the demand is set aside and the tax becomes refundable. That provision covers refunds not specifically falling within Section 244A(1)(a) and requires interest from the date of tax payment until the refund is granted. Section 244A(1B), inserted subsequently, does not deny interest otherwise payable under the pre-existing provision. Revenue retention of money without legal entitlement carries a corresponding obligation to refund the amount with statutory interest.
Interest on refunds of tax paid under a TDS-default demand is governed by Section 244A(1)(b) where the demand is set aside and the tax becomes refundable. That provision covers refunds not specifically falling within Section 244A(1)(a) and requires interest from the date of tax payment until the refund is granted. Section 244A(1B), inserted subsequently, does not deny interest otherwise payable under the pre-existing provision. Revenue retention of money without legal entitlement carries a corresponding obligation to refund the amount with statutory interest.
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