Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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