Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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