Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
Rejection of refund on the ground of delay - time limitation - The High Court examined the timeline of the refund applications in light of the Covid-19 pandemic's impact on statutory limitations. It noted that the applications were indeed filed within the extended timeframe provided by the Government Notification No.13 of 2022, which suspended limitations from February 15, 2020, to February 28, 2022. The Court cited a precedent case, Gamma Gaana Ltd. vs. Union of India, to reinforce this interpretation. - The Court directed the authority to process the refund applications without objections regarding delay.
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