OthersArticle·24 April 2026
Refund Vs Limitation
By J the App
Executive Summary
Where tax is paid under a mistaken understanding, especially based on departmental audit instructions, and the underlying transaction is later found non-taxable, the department cannot unjustly retain such amounts.
Procedural barriers like limitation or failure to appeal refund rejection cannot override substantive entitlement to refund, nor can they invalidate self-adjustment.
Issues for Determination
The Court examined whether profit share from foreign exchange transactions constitutes a taxable se...
Read the full article in the app
This is a premium article. Download J the App to read the complete content.