Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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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