Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
Rejection of a tax refund claim as time-barred was held unsustainable because the record showed the claimant had filed an initial refund application on 09.05.2023 within the statutory period for January 2019 to March 2021, and also filed a further claim on 28.02.2024, the date the authority itself treated as the outer limit, yet neither filing was duly considered. The authority also failed to apply the Covid-19 limitation exclusion under Notification No. 13/2022, covering March 2020 to February 2022, which operated to extend limitation. The refund applications were held within time and the impugned order was set aside. - HC
Rejection of a tax refund claim as time-barred was held unsustainable because the record showed the claimant had filed an initial refund application on 09.05.2023 within the statutory period for January 2019 to March 2021, and also filed a further claim on 28.02.2024, the date the authority itself treated as the outer limit, yet neither filing was duly considered. The authority also failed to apply the Covid-19 limitation exclusion under Notification No. 13/2022, covering March 2020 to February 2022, which operated to extend limitation. The refund applications were held within time and the impugned order was set aside. - HC
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