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...
The High Court allowed the petition and directed the tax authorities to accept the petitioner's Forms 1 and 2 under the Direct Tax Vivad Se Vishwas Act and issue a fresh Certificate in Form 3 within four weeks, granting waiver of the entire interest amount determined in the assessment orders. The Court held that no distinction has been made between waiver of interest on disputed taxes and interest on tax not in dispute u/s 3 of the Act. The tax authorities had erroneously calculated interest by not granting complete waiver, which was contrary to the provisions of the Act. The petitioner undertook to withdraw pending appeals/rectification applications expeditiously.
The High Court allowed the petition and directed the tax authorities to accept the petitioner's Forms 1 and 2 under the Direct Tax Vivad Se Vishwas Act and issue a fresh Certificate in Form 3 within four weeks, granting waiver of the entire interest amount determined in the assessment orders. The Court held that no distinction has been made between waiver of interest on disputed taxes and interest on tax not in dispute u/s 3 of the Act. The tax authorities had erroneously calculated interest by not granting complete waiver, which was contrary to the provisions of the Act. The petitioner undertook to withdraw pending appeals/rectification applications expeditiously.
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