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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The SC upheld that interest liability on penalties imposed under the SEBI Act arises from the expiry of the compliance period specified in the adjudication order, here 45 days from 28.08.2014, not from subsequent demand notices. Section 28A of the SEBI Act, along with Explanation 4 inserted in 2019, clarifies that interest accrues from the date the amount became payable, which is triggered by the adjudication order itself when it specifies the payment timeline. The interest is compensatory, aimed at compensating revenue loss due to delayed payment, not punitive. Separate demand notices are redundant where the adjudication order fixes the payment period. The appellants' contention to defer interest liability until formal demand notices is rejected as it would undermine enforcement and revenue protection. The appeals were dismissed, directing payment of interest as computed by the respondent within 15 days, with no costs awarded.
The SC upheld that interest liability on penalties imposed under the SEBI Act arises from the expiry of the compliance period specified in the adjudication order, here 45 days from 28.08.2014, not from subsequent demand notices. Section 28A of the SEBI Act, along with Explanation 4 inserted in 2019, clarifies that interest accrues from the date the amount became payable, which is triggered by the adjudication order itself when it specifies the payment timeline. The interest is compensatory, aimed at compensating revenue loss due to delayed payment, not punitive. Separate demand notices are redundant where the adjudication order fixes the payment period. The appellants' contention to defer interest liability until formal demand notices is rejected as it would undermine enforcement and revenue protection. The appeals were dismissed, directing payment of interest as computed by the respondent within 15 days, with no costs awarded.
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