Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
HC held that the refund claim's date of origin, not the formal application date, determines delay calculation. The court emphasized that when a refund request is made within an Income Tax Return, that date becomes the reference point for assessing delay and potential condonation. The delay from 1.4.2012 to 13.7.2012 (104 days) was considered. While the refund might be granted, no interest would be payable under section 244A due to the petitioner's eight-year delay. However, if the refund is not processed within six weeks of eligibility determination, interest would become applicable.
HC held that the refund claim's date of origin, not the formal application date, determines delay calculation. The court emphasized that when a refund request is made within an Income Tax Return, that date becomes the reference point for assessing delay and potential condonation. The delay from 1.4.2012 to 13.7.2012 (104 days) was considered. While the refund might be granted, no interest would be payable under section 244A due to the petitioner's eight-year delay. However, if the refund is not processed within six weeks of eligibility determination, interest would become applicable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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