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 the Revenue's refusal to process the petitioner's tax refund claim was unwarranted. The court found no valid basis for treating the revised return as defective, as no formal communication of defectiveness was issued. The TDS discrepancy alone cannot invalidate the return. The HC directed the Revenue to process the refund application, allowing the petitioner to file a rectification application based on Form 26AS. The assessment order under Section 153C does not prejudice the petitioner's right to claim the refund. The petition was disposed of with a binding direction to the Revenue to process the refund claim.
HC held that the Revenue's refusal to process the petitioner's tax refund claim was unwarranted. The court found no valid basis for treating the revised return as defective, as no formal communication of defectiveness was issued. The TDS discrepancy alone cannot invalidate the return. The HC directed the Revenue to process the refund application, allowing the petitioner to file a rectification application based on Form 26AS. The assessment order under Section 153C does not prejudice the petitioner's right to claim the refund. The petition was disposed of with a binding direction to the Revenue to process the refund claim.
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