Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
The dominant issue was whether an assessee is entitled to interest for a substantial delay in receiving a refund granted under the Direct Tax Vivad Se Vishwas Act, 2020, and whether "interest on interest" is payable. Relying on binding precedent recognising compensation for delayed refunds and permitting interest on the interest component where refund is unlawfully withheld, the Court held that the revenue could not deny statutory/compensatory interest merely because the refund had been sanctioned but not paid. Consequently, a writ of mandamus was issued directing payment of interest at 6% p.a. on the delayed refund from 25-05-2021 till 10-01-2024, along with interest on such interest. - HC
The dominant issue was whether an assessee is entitled to interest for a substantial delay in receiving a refund granted under the Direct Tax Vivad Se Vishwas Act, 2020, and whether "interest on interest" is payable. Relying on binding precedent recognising compensation for delayed refunds and permitting interest on the interest component where refund is unlawfully withheld, the Court held that the revenue could not deny statutory/compensatory interest merely because the refund had been sanctioned but not paid. Consequently, a writ of mandamus was issued directing payment of interest at 6% p.a. on the delayed refund from 25-05-2021 till 10-01-2024, along with interest on such interest. - HC
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