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seven. Statutory curiosity less than Segment 244A on the Act is payable about the refund of extra curiosity paid out below Sections 234A-C of your Act.

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In GE Capital, the Evaluating Officer observed inside the Area 241A order which the assessee firm was mainly a conduit setup in Mauritius for averting the payment of capital gains tax because of the parent business located in the united kingdom. That, the DTAA concerning India and British isles would Generally be relevant and tax will be payable. This, the Hon’ble Courtroom held may very well be inside the teeth on the judgment in UOI vs. Azadi Bacchao Andolan . But nevertheless, it determined to not interfere in evaluation proceedings if statutory demands ended up satisfied and prima facie factors did exist why refund was getting withheld.

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eight. The CBDT reserves the power to look at any grievance arising out of an buy passed or not handed by the authorities stated in para one previously mentioned and challenge suited directions to them for right implementation on the Round.

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It might be independently gathered and numerous actions of coercive Restoration are already delivered beneath the Act.

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