Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
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Entitlement to compensatory interest on delayed customs refunds arises under Section 27A and the statute mandates interest from the day after three months from receipt of the refund application; a deeming fiction in law does not postpone that commencement. The Department's wrongful rejection and protracted adjudication cannot defeat this statutory right, and denial of interest on the ground that refund was sanctioned only after appellate orders is unsustainable. Consequently the appellant is entitled to interest from the expiry of three months from each original refund application date in 2003 until actual payment, and the adjudicating authority was directed to compute and pay it promptly.
Entitlement to compensatory interest on delayed customs refunds arises under Section 27A and the statute mandates interest from the day after three months from receipt of the refund application; a deeming fiction in law does not postpone that commencement. The Department's wrongful rejection and protracted adjudication cannot defeat this statutory right, and denial of interest on the ground that refund was sanctioned only after appellate orders is unsustainable. Consequently the appellant is entitled to interest from the expiry of three months from each original refund application date in 2003 until actual payment, and the adjudicating authority was directed to compute and pay it promptly.
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