Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
Issue: Whether interest under section 234A is leviable where the original return was belated but a return filed in response to a section 153C notice was timely. Reasoning: Section 234A(1) charges interest for delay in filing the original return based on tax as determined under section 143(1) or a regular assessment; Explanation 3 treats an assessment made for the first time under section 153A (including assessments pursuant to section 153C) as a regular assessment for section 234A purposes. Outcome: Interest under section 234A was correctly computed and sustained. - ITAT
Issue: Whether interest under section 234A is leviable where the original return was belated but a return filed in response to a section 153C notice was timely. Reasoning: Section 234A(1) charges interest for delay in filing the original return based on tax as determined under section 143(1) or a regular assessment; Explanation 3 treats an assessment made for the first time under section 153A (including assessments pursuant to section 153C) as a regular assessment for section 234A purposes. Outcome: Interest under section 234A was correctly computed and sustained. - ITAT
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