Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC allowed the writ petition, setting aside the respondent's order rejecting the petitioner's application to rectify Form-3 under the Direct Tax Vivad Se Vishwas Act, 2020. The court interpreted Sections 2(j), 2(o), and 3 of the Act, determining that the petitioner is liable to pay only half the calculated tax amount. The court also clarified that if the petitioner had paid excess tax under the Income Tax Act, 1961, they would be entitled to a refund without interest, subject to the provisions of Section 7 of the Act.
HC allowed the writ petition, setting aside the respondent's order rejecting the petitioner's application to rectify Form-3 under the Direct Tax Vivad Se Vishwas Act, 2020. The court interpreted Sections 2(j), 2(o), and 3 of the Act, determining that the petitioner is liable to pay only half the calculated tax amount. The court also clarified that if the petitioner had paid excess tax under the Income Tax Act, 1961, they would be entitled to a refund without interest, subject to the provisions of Section 7 of the Act.
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