Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Interest under section 244A on a refund claimed through a return filed after the statutory deadline depends on the return's validity and prior condonation of delay. A return filed late without a preceding condonation application is treated as invalid for this purpose. Clause (ii) of paragraph 6 of the CBDT circular applies generally to belated refund claims, rather than only to supplementary refund claims, when read with the circular's preceding provisions. Statutory interest is therefore unavailable on refunds claimed through such belated returns.
Interest under section 244A on a refund claimed through a return filed after the statutory deadline depends on the return's validity and prior condonation of delay. A return filed late without a preceding condonation application is treated as invalid for this purpose. Clause (ii) of paragraph 6 of the CBDT circular applies generally to belated refund claims, rather than only to supplementary refund claims, when read with the circular's preceding provisions. Statutory interest is therefore unavailable on refunds claimed through such belated returns.
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