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...
HC ruled that assessment proceedings were time-barred due to excessive delay in passing remand order by ITAT. The AO failed to issue consequential order within prescribed limitation period. Court directed respondents to grant tax refund for AY 2005-06 with applicable interest under Sections 244A(1) and 244A(1A). The return is deemed accepted, and revenue must process the refund claim expeditiously, preferably within twelve weeks, following precedents in similar cases involving procedural limitations in tax assessment proceedings.
HC ruled that assessment proceedings were time-barred due to excessive delay in passing remand order by ITAT. The AO failed to issue consequential order within prescribed limitation period. Court directed respondents to grant tax refund for AY 2005-06 with applicable interest under Sections 244A(1) and 244A(1A). The return is deemed accepted, and revenue must process the refund claim expeditiously, preferably within twelve weeks, following precedents in similar cases involving procedural limitations in tax assessment proceedings.
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