Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
An amount paid during investigation was treated as a refundable deposit, not a voluntary duty payment, because the assessee had consistently disputed liability and the payment was made under a mistaken impression at the insistence of Revenue. Once the proceedings were dropped, the Tribunal held that refund of the investigation deposit carried interest as a matter of course. Applying its earlier authorities, it further held that interest was payable at 12% from the date of deposit until refund, and the denial of interest was set aside.
An amount paid during investigation was treated as a refundable deposit, not a voluntary duty payment, because the assessee had consistently disputed liability and the payment was made under a mistaken impression at the insistence of Revenue. Once the proceedings were dropped, the Tribunal held that refund of the investigation deposit carried interest as a matter of course. Applying its earlier authorities, it further held that interest was payable at 12% from the date of deposit until refund, and the denial of interest was set aside.
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