Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
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