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HC set aside rejection order dated 30.10.2024 concerning DTVSV Form-1 application involving interest charges under Sections 234A, 234B, and 234C. Following precedents established in Kapri International and Tvl. Sanmac Mootor Finance Ltd., the court directed CIT to reassess petitioner's declaration under DTVSV Scheme. Revenue's inability to confirm any Supreme Court challenge to Kapri International judgment rendered it binding precedent. Court determined ratio decidendi of Kapri International applicable to present case, mandating fresh examination of declaration per DTVSV Act and Rules procedures. Matter remanded for merit-based reassessment by tax authorities.
HC set aside rejection order dated 30.10.2024 concerning DTVSV Form-1 application involving interest charges under Sections 234A, 234B, and 234C. Following precedents established in Kapri International and Tvl. Sanmac Mootor Finance Ltd., the court directed CIT to reassess petitioner's declaration under DTVSV Scheme. Revenue's inability to confirm any Supreme Court challenge to Kapri International judgment rendered it binding precedent. Court determined ratio decidendi of Kapri International applicable to present case, mandating fresh examination of declaration per DTVSV Act and Rules procedures. Matter remanded for merit-based reassessment by tax authorities.
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