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...
Statutory interest on customs refund depends on whether the refund was processed within the period under Section 27A and whether any delay in re-assessment is attributable to the Department. Where refund claims became maintainable only after prior directions and the refund orders were issued within three months of the applications, the Court held that no interest was payable. By contrast, where petitioners had sought re-assessment long earlier and the Department's prolonged delay in passing re-assessment orders delayed the refund, the Court directed statutory interest from the date of the first re-assessment application until actual refund.
Statutory interest on customs refund depends on whether the refund was processed within the period under Section 27A and whether any delay in re-assessment is attributable to the Department. Where refund claims became maintainable only after prior directions and the refund orders were issued within three months of the applications, the Court held that no interest was payable. By contrast, where petitioners had sought re-assessment long earlier and the Department's prolonged delay in passing re-assessment orders delayed the refund, the Court directed statutory interest from the date of the first re-assessment application until actual refund.
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