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    <title>2023 (7) TMI 41 - Supreme Court</title>
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    <description>An illustration to Rule 67 of the A.P. VAT Rules could not override Section 69 or the substantive rule it was meant to explain, so the 2009 amendment correcting the illustration to align with the statutory scheme was valid. Section 69 and Rule 67 continued the deferment benefit for eligible tax holiday units by converting them into deferment units for the balance period available as on 31.03.2005, doubled under the rule. However, interest and penalty were not leviable for the transitional period from 01.04.2005 to May 2009 on the deferred tax liability, because the liability had not crystallised under the operative understanding then prevailing. Any amounts already recovered on that basis were directed to be refunded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=439768</link>
      <description>An illustration to Rule 67 of the A.P. VAT Rules could not override Section 69 or the substantive rule it was meant to explain, so the 2009 amendment correcting the illustration to align with the statutory scheme was valid. Section 69 and Rule 67 continued the deferment benefit for eligible tax holiday units by converting them into deferment units for the balance period available as on 31.03.2005, doubled under the rule. However, interest and penalty were not leviable for the transitional period from 01.04.2005 to May 2009 on the deferred tax liability, because the liability had not crystallised under the operative understanding then prevailing. Any amounts already recovered on that basis were directed to be refunded.</description>
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