Court Clarifies Precedent Application in SAD Refunds: Favorable Interpretation for Assessees in Time-Limited Cases.

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....Applicability of precedent judgements - Refund of SAD - rejection on the ground of time limitation - Doctrine of precedence only mandates that it is the ratio in the decision of higher courts to be followed, and not conclusions - when there is a reasonable interpretation of a legal and factual situation, which is favourable to the assessee, such an interpretation is to be adopted. - AT....