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 HC allowed the petition, setting aside the impugned order dated 09.09.2024, and directed respondents to refund the contested amount with statutory interest at 6% per annum from the date the order of the First Authority became operative, on the ground that the refund was not made within 60 days of that order. The court rejected respondents' plea to attract the higher 9% rate, noting petitioners sought only 6% and that the Appellate Authority had quashed the original rejection dated 14.09.2020. The HC held the rejection to be unlawful and confirmed entitlement to the specified interest on the delayed refund.
The HC allowed the petition, setting aside the impugned order dated 09.09.2024, and directed respondents to refund the contested amount with statutory interest at 6% per annum from the date the order of the First Authority became operative, on the ground that the refund was not made within 60 days of that order. The court rejected respondents' plea to attract the higher 9% rate, noting petitioners sought only 6% and that the Appellate Authority had quashed the original rejection dated 14.09.2020. The HC held the rejection to be unlawful and confirmed entitlement to the specified interest on the delayed refund.
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