Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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Rectification u/s 154 - refund of taxes paid in foreign country - The High court noted that the Hon'ble Apex Court had expressly overruled the AAR order in a previous case involving the petitioner, which entitled the petitioner to seek rectification and refund of taxes paid under protest. - The court emphasized the importance of the circular dated 17.11.1971, which allows rectification of returns based on the interpretation of law by the Hon'ble Apex Court. - Consequently, the court allowed the petition, set aside the impugned order, and directed the concerned respondents to refund the taxes paid by the petitioner along with applicable interest.
Rectification u/s 154 - refund of taxes paid in foreign country - The High court noted that the Hon'ble Apex Court had expressly overruled the AAR order in a previous case involving the petitioner, which entitled the petitioner to seek rectification and refund of taxes paid under protest. - The court emphasized the importance of the circular dated 17.11.1971, which allows rectification of returns based on the interpretation of law by the Hon'ble Apex Court. - Consequently, the court allowed the petition, set aside the impugned order, and directed the concerned respondents to refund the taxes paid by the petitioner along with applicable interest.
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