TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Interest on refunds of tax paid under a TDS-default demand is governed by Section 244A(1)(b) where the demand is set aside and the tax becomes refundable. That provision covers refunds not specifically falling within Section 244A(1)(a) and requires interest from the date of tax payment until the refund is granted. Section 244A(1B), inserted subsequently, does not deny interest otherwise payable under the pre-existing provision. Revenue retention of money without legal entitlement carries a corresponding obligation to refund the amount with statutory interest.
Interest on refunds of tax paid under a TDS-default demand is governed by Section 244A(1)(b) where the demand is set aside and the tax becomes refundable. That provision covers refunds not specifically falling within Section 244A(1)(a) and requires interest from the date of tax payment until the refund is granted. Section 244A(1B), inserted subsequently, does not deny interest otherwise payable under the pre-existing provision. Revenue retention of money without legal entitlement carries a corresponding obligation to refund the amount with statutory interest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
