Refund limitation where demand covers multiple periods; taxpayers may restrict appeals to unaffected periods to preserve segmented adjudication. Amendments to Rule 164 condition refund availability on payment of tax related to the specified period and disallow refunds for tax, interest, and penalty already discharged for an entire period prior to these amendments where a notice or order aggregates demands partly for the specified period and partly for other periods. The amendment also allows a taxpayer to intimate the appellate authority that they will not pursue the appeal for the specified period, enabling the authority to adjudicate only the remaining period while treating the intimation as a partial withdrawal for the defined past period.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Refund limitation where demand covers multiple periods; taxpayers may restrict appeals to unaffected periods to preserve segmented adjudication.
Amendments to Rule 164 condition refund availability on payment of tax related to the specified period and disallow refunds for tax, interest, and penalty already discharged for an entire period prior to these amendments where a notice or order aggregates demands partly for the specified period and partly for other periods. The amendment also allows a taxpayer to intimate the appellate authority that they will not pursue the appeal for the specified period, enabling the authority to adjudicate only the remaining period while treating the intimation as a partial withdrawal for the defined past period.
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