Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
From 01.10.2025, refund claims for zero-rated supplies-and provisionally for inverted duty structure claims as an interim measure-will be processed using system risk scores: "low-risk" claims will receive 90% provisional sanction, while non-low-risk claims undergo detailed scrutiny. A proper officer may, with reasons recorded, refuse provisional sanction and inspect the claim. Certain notified categories remain ineligible for provisional refunds and statutory conditions (including non-prosecution requirements) apply. If provisional amounts exceed final admissible refunds, recovery proceedings via show-cause notice will follow. The measures are subject to monitoring by jurisdictional tax leadership and apply to claims filed on or after 01.10.2025.
From 01.10.2025, refund claims for zero-rated supplies-and provisionally for inverted duty structure claims as an interim measure-will be processed using system risk scores: "low-risk" claims will receive 90% provisional sanction, while non-low-risk claims undergo detailed scrutiny. A proper officer may, with reasons recorded, refuse provisional sanction and inspect the claim. Certain notified categories remain ineligible for provisional refunds and statutory conditions (including non-prosecution requirements) apply. If provisional amounts exceed final admissible refunds, recovery proceedings via show-cause notice will follow. The measures are subject to monitoring by jurisdictional tax leadership and apply to claims filed on or after 01.10.2025.
Note: It is a system-generated summary and is for quick reference only.