Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Claim of Interest on Refund u/s 7 of the DTVSV Act, 2020 - The High court determined that the petitioner was entitled to refunds as quantified in the Rectification Order dated 29.01.2021. However, it was held that interest under Section 244-A of the IT Act, 1961, was not permissible in light of the DTVSV Act, 2020's provisions, particularly the explanation to Section 7 which precludes interest on excess amounts refunded under the Act. - The court noted the petitioner's adjustments of refunds from later Assessment Years towards the payable amounts for earlier years were acknowledged. However, the court declined the recognition of interest on these adjustments as per the DTVSV Act, 2020.
Claim of Interest on Refund u/s 7 of the DTVSV Act, 2020 - The High court determined that the petitioner was entitled to refunds as quantified in the Rectification Order dated 29.01.2021. However, it was held that interest under Section 244-A of the IT Act, 1961, was not permissible in light of the DTVSV Act, 2020's provisions, particularly the explanation to Section 7 which precludes interest on excess amounts refunded under the Act. - The court noted the petitioner's adjustments of refunds from later Assessment Years towards the payable amounts for earlier years were acknowledged. However, the court declined the recognition of interest on these adjustments as per the DTVSV Act, 2020.
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