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Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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HC held that a refund order was unsustainable where it granted refund but did not consider or decide the petitioners' separate claim for accrued interest. The absence of any finding or reason on the interest component showed non-application of mind and failure to pass a reasoned order on an independent claim. The Court did not decide entitlement to interest on merits; it remitted the interest claim for fresh consideration and adjudication in accordance with law, after granting a personal hearing and leaving all contentions open.
HC held that a refund order was unsustainable where it granted refund but did not consider or decide the petitioners' separate claim for accrued interest. The absence of any finding or reason on the interest component showed non-application of mind and failure to pass a reasoned order on an independent claim. The Court did not decide entitlement to interest on merits; it remitted the interest claim for fresh consideration and adjudication in accordance with law, after granting a personal hearing and leaving all contentions open.
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