Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
The text addresses denial of income tax refund applications where rejection rested solely on delay without applying the Supreme Court's exclusion of the limitation period from 15.03.2020 to 28.02.2022; the legal principle applied is that administrative refusals cannot ignore a binding judicial exclusion of limitation. Outcome: the impugned deficiency memos were quashed and the refund claims remitted for fresh, expeditious consideration in accordance with the exclusion, after affording the claimants a reasonable hearing and issuing a reasoned, speaking order.
The text addresses denial of income tax refund applications where rejection rested solely on delay without applying the Supreme Court's exclusion of the limitation period from 15.03.2020 to 28.02.2022; the legal principle applied is that administrative refusals cannot ignore a binding judicial exclusion of limitation. Outcome: the impugned deficiency memos were quashed and the refund claims remitted for fresh, expeditious consideration in accordance with the exclusion, after affording the claimants a reasonable hearing and issuing a reasoned, speaking order.
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