Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Interest on delayed refund - relevant time for calculation of interest - Considering Section 30 of the Act, which stipulates interest on delayed refunds, the court examined both parties' submissions. The court held that the petitioner had made the refund claim within the stipulated time frame, and there was no evidence of delay attributable to them. Therefore, the petitioner was entitled to interest on the delayed refund.
Interest on delayed refund - relevant time for calculation of interest - Considering Section 30 of the Act, which stipulates interest on delayed refunds, the court examined both parties' submissions. The court held that the petitioner had made the refund claim within the stipulated time frame, and there was no evidence of delay attributable to them. Therefore, the petitioner was entitled to interest on the delayed refund.
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