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 under section 244A on a refund claimed through a return filed after the statutory deadline depends on the return's validity and prior condonation of delay. A return filed late without a preceding condonation application is treated as invalid for this purpose. Clause (ii) of paragraph 6 of the CBDT circular applies generally to belated refund claims, rather than only to supplementary refund claims, when read with the circular's preceding provisions. Statutory interest is therefore unavailable on refunds claimed through such belated returns.
Interest under section 244A on a refund claimed through a return filed after the statutory deadline depends on the return's validity and prior condonation of delay. A return filed late without a preceding condonation application is treated as invalid for this purpose. Clause (ii) of paragraph 6 of the CBDT circular applies generally to belated refund claims, rather than only to supplementary refund claims, when read with the circular's preceding provisions. Statutory interest is therefore unavailable on refunds claimed through such belated returns.
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