Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
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...
Section 27A of the Customs Act requires interest on delayed customs-duty refunds where the refund is not paid within three months of receipt of the refund application. An appellate order allowing refund is deemed an order under section 27(2), but that deeming provision does not defer the commencement of interest. Where a refund application preceded appellate litigation, statutory interest accrues from expiry of three months after the application until the date of refund payment, despite the refund being granted following the litigation.
Section 27A of the Customs Act requires interest on delayed customs-duty refunds where the refund is not paid within three months of receipt of the refund application. An appellate order allowing refund is deemed an order under section 27(2), but that deeming provision does not defer the commencement of interest. Where a refund application preceded appellate litigation, statutory interest accrues from expiry of three months after the application until the date of refund payment, despite the refund being granted following the litigation.
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