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    <title>2026 (8) TMI 565 - MADRAS HIGH COURT</title>
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    <description>Compounding fee must be recomputed under the CBDT Guidelines dated 16.05.2008 because their applicability had already been conclusively determined between the parties and affirmed in appeal. A direction to calculate and communicate the fee concerned quantification only and could not reopen the settled governing framework. The power to issue compounding instructions cannot displace a final inter partes judicial determination. The revised 2024 Guidelines were also inapplicable because the compounding application had not been rejected for a curable defect contemplated by those Guidelines. The recomputation must credit the amount already paid by the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=796692</link>
      <description>Compounding fee must be recomputed under the CBDT Guidelines dated 16.05.2008 because their applicability had already been conclusively determined between the parties and affirmed in appeal. A direction to calculate and communicate the fee concerned quantification only and could not reopen the settled governing framework. The power to issue compounding instructions cannot displace a final inter partes judicial determination. The revised 2024 Guidelines were also inapplicable because the compounding application had not been rejected for a curable defect contemplated by those Guidelines. The recomputation must credit the amount already paid by the assessee.</description>
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