Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT ruled that taxpayer is entitled to interest on refund arising from excess self-assessment tax u/s 244A(1)(b), despite the specific provision 244A(1)(aa) being introduced later by Finance Act 2016. The amendment was clarificatory in nature, not restrictive. Due to 68-month delay in refund processing (December 2014 to July 2020), ITAT granted additional interest @3% per annum u/s 244A(1A), but only from June 1, 2016 (effective date of amendment) until refund date. This aligns with precedent set in Stock Holding Corporation case and Nima Specific Family Trust ruling. Taxpayer's appeal for additional interest partially allowed; revenue's appeal dismissed.
ITAT ruled that taxpayer is entitled to interest on refund arising from excess self-assessment tax u/s 244A(1)(b), despite the specific provision 244A(1)(aa) being introduced later by Finance Act 2016. The amendment was clarificatory in nature, not restrictive. Due to 68-month delay in refund processing (December 2014 to July 2020), ITAT granted additional interest @3% per annum u/s 244A(1A), but only from June 1, 2016 (effective date of amendment) until refund date. This aligns with precedent set in Stock Holding Corporation case and Nima Specific Family Trust ruling. Taxpayer's appeal for additional interest partially allowed; revenue's appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
