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...
Non-granting interest u/s 244A on excess self-assessment tax from January 2017 to October 2017 was denied, citing the refund was less than 10% of the tax determined in regular assessment u/s 143(3). The assessee argued the self-assessment tax, adjusted against the demand raised in assessment, lost its character. The Tribunal agreed with the assessee's contention, referring to the decision in AWP Assistance (I) Pvt. Ltd. Once adjusted against the tax liability determined in regular assessment, the self-assessment tax no longer retained its character under sub-clause (aa) of Section 244A(1). After adjustment, the refund fell under sub-clause (b) of Section 244A(1), not hit by the proviso denying interest where refund is below 10%. Consequently, the assessee is entitled to interest on the refund of self-assessment tax for January 2017 to October 2017.
Non-granting interest u/s 244A on excess self-assessment tax from January 2017 to October 2017 was denied, citing the refund was less than 10% of the tax determined in regular assessment u/s 143(3). The assessee argued the self-assessment tax, adjusted against the demand raised in assessment, lost its character. The Tribunal agreed with the assessee's contention, referring to the decision in AWP Assistance (I) Pvt. Ltd. Once adjusted against the tax liability determined in regular assessment, the self-assessment tax no longer retained its character under sub-clause (aa) of Section 244A(1). After adjustment, the refund fell under sub-clause (b) of Section 244A(1), not hit by the proviso denying interest where refund is below 10%. Consequently, the assessee is entitled to interest on the refund of self-assessment tax for January 2017 to October 2017.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
