Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Delay in issuing Refund under Direct Tax Vivad Se Vishwas Scheme 2020 - interest on delayed refund - Despite the issuance of Form No. 5, the refunds for the Assessment years 2010-11 and 2012-13 were not promptly processed, leading to grievances from the petitioner. - The High Court examined the circumstances and precedent, noting that the delay in issuing refunds was not adequately explained by the department. Relying on the principles established in the Tata Chemicals case, the court concluded that the petitioner was entitled to interest on the delayed refunds.
Delay in issuing Refund under Direct Tax Vivad Se Vishwas Scheme 2020 - interest on delayed refund - Despite the issuance of Form No. 5, the refunds for the Assessment years 2010-11 and 2012-13 were not promptly processed, leading to grievances from the petitioner. - The High Court examined the circumstances and precedent, noting that the delay in issuing refunds was not adequately explained by the department. Relying on the principles established in the Tata Chemicals case, the court concluded that the petitioner was entitled to interest on the delayed refunds.
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TaxTMI 
TaxTMI 
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