TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC held that upon successful appeal, the tax authority is obligated to refund the recovered amount under Income Tax Act provisions. The court directed the respondent to refund the entire recovered amount within seven days, with a stipulation that any delayed refund shall accrue interest at 6% per annum from the date of initial recovery until actual refund. The ruling affirms the petitioner's right to monetary restoration following the setting aside of the reassessment order under section 147, emphasizing procedural fairness and compensatory interest for unwarranted financial detention.
HC held that upon successful appeal, the tax authority is obligated to refund the recovered amount under Income Tax Act provisions. The court directed the respondent to refund the entire recovered amount within seven days, with a stipulation that any delayed refund shall accrue interest at 6% per annum from the date of initial recovery until actual refund. The ruling affirms the petitioner's right to monetary restoration following the setting aside of the reassessment order under section 147, emphasizing procedural fairness and compensatory interest for unwarranted financial detention.
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