Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The article addresses whether interest under section 244A of the Income-tax Act applies to tax refunds determined under the Direct Tax Vivad se Vishwas Act (DTVSV). Applying precedent that treats a DTVSV-determined amount as a tax refund, the analysis concludes that where the Revenue retained funds without right, statutory entitlement to interest follows; the DTVSV Explanation concerning pre-declaration payments does not negate post-Form No.5 interest. The conclusion directs revenue authorities to grant interest for delay beyond the statutory period on refunds determined under DTVSV for the specified assessment years.
The article addresses whether interest under section 244A of the Income-tax Act applies to tax refunds determined under the Direct Tax Vivad se Vishwas Act (DTVSV). Applying precedent that treats a DTVSV-determined amount as a tax refund, the analysis concludes that where the Revenue retained funds without right, statutory entitlement to interest follows; the DTVSV Explanation concerning pre-declaration payments does not negate post-Form No.5 interest. The conclusion directs revenue authorities to grant interest for delay beyond the statutory period on refunds determined under DTVSV for the specified assessment years.
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