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2016 (1) TMI 940 - ITAT AHMEDABAD

2016 (1) TMI 940 - ITAT AHMEDABAD - TMI - Credit of taxes paid and set off of MAT credit as per the provisions of section 115JAA - Pro rata quantification of the demerged undertaking MAT, TDS and advance tax credits - Held that:- As once the demerged gas distribution undertaking no more exists w.e.f. 01-01-2007 coming to be the appointed day, the assessee-resulting company is entitled for all the pro rata adjustments of TDS, advance tax and MAT credits as per law; to be utilized in former's acco .....

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S. Godara, JM For the Appellant : Shri James Kurian, Sr. DR For the Respondent : Shri S N Soparkar, AR ORDER Per S. S. Godara, Judicial Member These two assessee's appeals for assessment year 2008-09, arise from two separate orders of the CIT(A)-VI, Ahmedabad dated 28-06-2011 and 02-08-2011 in appeal nos CIT(A)-VI-Cir-1/332/10-11 and CIT(A)-VI-Cir-1/289/10-11, in proceedings under section 154 and 143(3) of the Income Tax Act, 1961; in short "the Act"; respectively. 2. The assessee .....

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hallenges disallowance of ₹ 10,28,028/- of preliminary expenditure u/s. 35D of the Act. This assessee is a company engaged in trading and transportation of natural gas, production of compressed natural gas and sale thereof. It amortized preliminary expenses of ₹ 10,28028/- u/s. 35D. The same comprised of a sum of ₹ 5 lacs @ 1/5 of ₹ 25 lacs incurred in AY 2005-06. The remaining figure of ₹ 5,28,028/- is @ 1/5 of ₹ 26,40,140/- similarly incurred earlier. Both t .....

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the lower appellate findings under challenge. 4. Heard both sides. Case records perused. Relevant facts qua the issue stated in preceding paragraphs are not repeated for the sake of brevity. Neither of the lower authority has specifically rejected assessee's contention based on fact that the very expenditure stands accepted in preceding assessment years. The hon'ble jurisdictional in (2014) 369 ITR 763 (Guj) Gujarat Narmada Valley Fertilizers Company Ltd Vs. DCIT as affirmed by the hon&# .....

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ground raised in the impugned appeal challenges prior period expenditure disallowance of ₹ 15,25,746/- made in both the lower proceedings. This claim includes professional fee sum of ₹ 10,10,160/-. The Assessing Officer observed that such a claim is allowable in the corresponding assessment year since there was no evidence of the same having been actually crystalized during the relevant previous year. The CIT(A) confirms the very view. 6. We have heard both the parties. There is no .....

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he case file. Both the lower authorities hold accordingly that the assessee has failed in proving crystallization of the impugned expenditure. Therefore, we do not find any merit in this crystallization plea based in the course of arguments before us. This second substantive ground fails. At this stage, the assessee raises an alternative argument that it is entitled to set off prior period income of ₹ 7,55,575/- against the above stated prior period expenditure. The relevant grounds pleade .....

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prior period expenditure. The Revenue fails in rebutting this proposition. We accordingly accept this alternative contention and direct the Assessing Officer to set off assessee's prior period expenditure and income as per law. He shall pass a consequential order accordingly. The assessee's third and fourth substantive grounds are accepted for statistical purposes. 7. The assessee's next three substantive grounds assail correctness of the lower appellate findings affirming Assessing .....

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n its written submission, which is as under: "In terms of the scheme of de-merger for assets, liabilities etc. of the respective undertakings sanctioned by the Hon'ble Gujarat High Court, there was bifurcation of income and taxes pertaining to the de-merged company i.e. Adani Energy Ltd. and the resultant company i.e. Adani Gas Ltd. The Energy limited has claimed refund of ₹ 17,11,442/- as per the original return of income but since the return of income was revised to give effect .....

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im of taxes paid in the revised return of income so that the total amount of refund is not less than ₹ 17,11,442/- along with interest thereon u/s 244A of the IT Act as claimed in the original return of income. Thus from the above the appellant would like to submit that the minimum amount of the MAT credit available for set off is ₹ 90.29 lacs as claimed in the Return of Income. In the event the additions as made under the assessment order are confirmed Your goodselves may direct the .....

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000 4. Total 2, 11,57,863 The total amount of the taxes paid by the appellant amount to ₹ 2,11,57,863. Due to demerger the entire credit was transferred to appellant company because the taxes resulted mainly from activities pertaining to the company. But on the perusal of order u/s 143(3) and notice of demand u/s 156 of appellant company it seems that appellant company has not been allotted the any credit of TDS. The Ld. A.O has proceeded to estimate the demand payable without giving this .....

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duction was made and credit shall be given to him for the amount so deducted on the production of the certificate furnished under section 203 in the assessment made under this Act for the assessment year for which such income is assessable"., The tax has been duly deducted by the payer and has fulfilled his obligations under section 200 and that tax deduction certificates have been issued under section 203. Thus the Assessing Officer should grant due credit to the appellant, on the basis of .....

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credits in accordance with the provisions of the law." 6.2 I have considered the facts of the case and appellant's submission. The Taxes have been paid prior to demerger by Adani energy Ltd. Appellant claimed credit of taxes paid including mat credit on the demerged part. However as per office note of the assessment order, it is seen that assessing officer allowed credit of taxes only in the hands of Adani energy Ltd since the demerger scheme approved by the High Court does not speak of .....

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e relevant scheme of arrangement is u/ss. 391 to 394 r.w.ss. 100 to 104 of the Companies Act, 1956. This scheme was presented before the hon'ble jurisdictional high court in company petition no. 205 of 2009 resulting in its approval vide order dated 19-11-2009. The appointed date therein is 01-01-2007. This demerger arrangement forms of the paper book at pages 14 to 44. It transpires that the same covers all assets and properties of the demerged undertaking followed by all of its debts, liab .....

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also not alleging any claim of double relief of the impugned credits. There can hardly be any quarrel that a demerger scheme comes under sections 391 to 394 of the Companies Act, 1956. We proceed further and find that section 2(19AA) of the Income Tax Act defines a demerger to be an arrangement under the above stated provisions of the Companies law meaning transfer of all properties of the undertaking immediately before the demerger becoming properties of the resulting company followed by corres .....

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The same is followed by much more an elaborate clause covering all possible benefits including deferred tax benefits. We observe in this factual backdrop that the CIT(A)'s findings go against the case record as well as the statutory meaning of a demerger quoted hereinabove not stipulating specific clause of bifurcation of tax credits in the scheme of arrangement approved u/ss. 391 to 394 of the Companies Act. 10. We come to case law quoted in course of arguments. The first one is (1997) 223 .....

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ary jurisdiction vested under article 226 of the Constitution of India. Hon'ble apex court elaborated effect of amalgamation under Companies Act as follows:- "8. Let us first examine the position obtaining in this behalf under the Companies Act. Sub-sections (1), (2) and (3) of section 391 (relevant for our purpose) and section 394 read: "Section 391. Power of compromise or make arrangements with creditors and members.- (I) Where a compromise or arrangement is proposed - (a) betwee .....

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esenting three-fourths in value of the creditors, or class of creditors, or members, or class of members, as the case may be, present and voting either in person or, where proxies are allowed under the rules made under section 643, by proxy, at die meeting, agree to any compromise or arrangement, the compromise or arrangement shall, if sanctioned by the Court, be binding on all the creditors, all the creditors of the class, all the members, or all the members of the class, as the case may be, an .....

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the latest auditor's report on the accounts of the company, the pendency of any investigation proceedings in relation to the company under sections 235 to 251, and the like. (3) An order made by the Court under sub-section (2) shall have no effect until a certified copy of the order has been filed with the Registrar." "Section 394. Provisions for facilitating reconstruction and amalgamation of companies.-(1) Where an application is made to the Court under section 391 for the sanct .....

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is section referred to as a 'transferor company') is to be transferred to another company (in this section referred to as 'the transferee company'); the Court may, either by the order sanctioning the compromise or arrangement or by a subsequent order, make provision for all or any of the following matters: (i)the transfer to the transferee company of the whole or any part of the undertaking, property or liabilities of any transferor company; (ii)the allotment or appropriation by .....

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the Court directs, dissent from the compromise or arrangement; and (vi)such incidental, consequential and supplemental matters as are necessary to secure that the reconstruction or amalgamation shall be fully and effectively carried out: Provided that no compromise or arrangement proposed for die purpose of, or in connection with, a scheme or the amalgamation of a company, which is being winding-up, with any other company or companies, shall be sanctioned by the Court unless the Court has recei .....

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udicial to the interest of its members or to public interest. (2) Where an order under this section provides for the transfer of any property or liabilities, then, by virtue of the order, that property shall be transferred to and vest in, and those liabilities shall be transferred to and become the liabilities of, the transferee company; and in the case of any property, if the order so directs, freed from any charge which is, by virtue of the compromise or arrangement, to cease to have effect. ( .....

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'liabilities' includes duties of every description; and (b)'transferee company' does not include any company, other than a company within the meaning of this Act; but 'transferor company' includes anybody corporate, whether a company within the meaning of this Act or not." 9. Section 394A of the Companies Act provides that on every application under section 391 or section 394, die Court shall give notice of such application to die Central Government and shall take in .....

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t to the facts of the case before us, may be summarised thus: (a)Where an amalgamation of two or more companies is proposed, an application has to be made to the Court for the purpose. Thereupon, the Court may call the meeting of members of the companies concerned. The order of the Court shall be in Form No. 3 5 prescribed by the Rules. (b)Such notice of the meeting has to be sent individually to all the members. (The notice and the explanatory statement under section 393 are settled by the offi .....

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satisfied that the applicants have disclosed all material facts fully and truly. (e)The application for confirmation made under sections 391(2) and 394 is also required to be advertised in the same newspapers in which the notice of the meeting was advertised and the notice is also required to be served on the Central Government as provided by section 394A. (f)If the Court is satisfied that the statutory formalities have been duly complied with and the scheme is fair and a reasonable one and ben .....

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) aforesaid, they shall take effect as provided in the order. (g)Within 30 days of the order sanctioning the amalgamation arrangement, the company concerned shall file a certified copy of the order before the Registrar for registration. This is made mandatory by the second limb of sub-section (3) of section 394. (h)The order sanctioning the scheme is required to be drawn up in accordance with Form Nos. 41 and 42 of the Companies [Court] Rules. 11. We may now refer to the scheme of amalgamation a .....

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t Calcutta". The expression 'the transfer date' is defined to mean '1st January, 1982' and the expression 'the operative date' means the date on which the certified copies of the orders of the High Courts of Tamil Nadu and Calcutta under section 391(2)/394(2) shall have been filed with the Registrars of Companies in Tamil Nadu and Calcutta, respectively. The expression 'terminal date' is defined to mean the date immediately preceding the operative date. The s .....

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t subject, nevertheless, to all charges affecting the same and on the said date, the transferor company shall be amalgamated with the transferee company. (2) to (5)******* 6.(a) The excess of the value of the net assets of the transferor company, based on the balance sheet of the transferor company as at the date immediately preceding the transfer date over its subscribed and paid-up capital shall, to the extent of the amount appearing as Development Rebate Reserve, Investment Allowance Reserve .....

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hall be deemed to be the profits or losses of the transferee company and shall be available to the transferee company for disposal in any manner including the declaration of any dividend by the transferee company after the operative date, subject to the provisions of the Act. 7. The implementation of this scheme is conditional upon this scheme being sanctioned under section 391 of the Act and the appropriate orders for implementation of this Scheme being made under section 394 of the Act by the .....

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sidiary company shall be transferred to the holding company with effect from the transferred date and that the subsidiary company shall be amalgamated with the holding company with effect from the said date. Clause 6 states clearly that the implementation of the said scheme "is conditional upon the scheme being sanctioned under section 391 of the Act and the appropriate orders for the implementation of this scheme being made under section 394 of the Act by the High Courts of Tamil Nadu and .....

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d with the date on which the shareholders of the subsidiary company become the shareholders of the holding company as provided in the subclauses. The High Court has opined that the transfer date mentioned in the scheme, viz., 1-1-1982, is "totally artificial and arbitrary" - for the reason that on the said date neither the company nor their shareholders had even thought of amalgamation and that it has no legal significance. According to the High Court, therefore, the date on which the .....

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lier Full Bench decision of that Court in Sahayanidhi (Virudhunagar) Ltd. v. AR.S. Subrahmanya Nadar [1950] 20 Comp. Cas. 214. The High Court also opined that the decision of the Bombay High Court in Swastik Rubber Products Ltd's case (supra) is of no assistance to the appellant. On this basis, the High Court has upheld the validity of the notices issued by the ITO, which nonces were impugned in the writ petition, and dismissed the writ petition. The question is whether the view taken by the .....

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te would be the date of amalgamation/date of transfer. But where the Court does not prescribe any specific date but merely sanctions the scheme presented to it - as has happened in this case - it should follow that the date of amalgamation/date of transfer is the date specified in the scheme as 'the transfer date'. It cannot be otherwise. It must be remembered that before applying to the Court under section 391(1), a scheme has to be framed and such scheme has to contain a date of amalga .....

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amation. In the scheme before us, clause 6(b) does expressly provide that with effect from the transfer date, the transferor company (subsidiary company) shall be deemed to have carried on the business for and on behalf of the transferee company (holding company) with all attendant consequences. It is equally relevant to notice that the Courts have not only sanctioned the scheme in this case but have also not specified any other date as the date of transfer/amalgamation. In such a situation, it .....

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heme of amalgamation as presented to it. The order of the Court sanctioning the scheme, the filing of the certified copies of the orders of the Court before the Registrar of Companies, the allotment of shares, etc., may have all taken place subsequent to the date of amalgamation/transfer, yet the date of amalgamation in the circumstances of this case would be 1-1-1982. This is also the ratio of the decision of the Privey Council in Raghubar Dayal v. Bank of Upper India Ltd. AIR 1919 PC 9. 13. Th .....

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make one assessment on the transferee company taking into account the income of both the transferor and transferee companies and also to make separate protective assessments on both the transferor and transferee companies separately. There may be a certain practical difficulty in adopting this course inasmuch as separate balance sheets may not be available of the transferor and transferee companies. But that may not be insuperable problem inasmuch as assessment can always be made, on the availab .....

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o more exists post facto the appointed date thereof coming to 01-01-2007 and the assessee being the resulting company, the former's MAT, TDS and advance tax credit are very much entitled to be considered in case of the latter assessee's entity since the former the demerged undertaking is deemed to have carried out its business, if any only on behalf of the assessee. The only rider that would flow our above stated discussion is that this entitlement of all these benefits would be confined .....

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ts share holding companies followed by its amalgamation with two of them. It filed a writ petition seeking refund of the above stated dividend distribution tax in view of the above stated amalgamation scheme. Their lordships accepted this plea as under:- "13. Coming to the merits of the petitioner's claim, we may recall that a total dividend of ₹ 53,90,62,500/- was paid by one Torrent Power Ltd to three different companies, namely, Torrent Investment Pvt. Ltd., Torrent Ltd. and To .....

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. 14. By now it is well settled that a merger or amalgamation scheme once sanctioned by the competent court would take effect from the date of the order envisaged in the scheme itself unless, of course, the court sanctioning such scheme otherwise provides. In the case of Marshall Sons and Co. (India) Ltd. (supra), the Apex Court observed as under: "Every scheme of amalgamation has to necessarily provide a date with effect from which the amalgamation transfer shall take place. The scheme con .....

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s has happened in this case - it should follow that the date of amalgamation/date of transfer is the date specified in the scheme as "the transfer date". It cannot be otherwise. It must be remembered that before applying to the Court under Section 391(1) a scheme has to be framed and such scheme has to contain a date of amalgamation/transfer. The proceedings before the Court may take sometime; indeed, they are bound to take some time because several steps provided by Sections 391 to 39 .....

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be deemed to have carried on the business for and on behalf of the Transferee Company (Holding Company) with all attendant consequences." In the case of Saraswati Industrial Syndicate Ltd. v. CIT AIR 1991 SC 70, the Apex Court on the question of amalgamation of two companies observed as under: 'Two companies may join to form a new company, but there may be absorption or blending of one by the other, both amount to amalgamation. When two companies are merged and are so joined as to form .....

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Ltd. (supra) and New Shorrock Spg. & Mfg. Co. Ltd., a company cannot pay dividend to its own self. In the case of Mafatlal Gagalbhai & Co. (P.) Ltd. (supra), the facts were that the assessee company had declared dividend and paid to another company which was a major shareholder of the assessee company. Even before declaration of dividend, negotiations were going on for amalgamation of both the companies. Both the companies, therefore, presented a scheme for amalgamation before the High C .....

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of the jute company with effect from 1st April 1968. It is trite kw that a company cannot hold shares of its own company. As a natural corollary, it cannot receive dividend out of its own profits. The High Court eventually held as under : "Evidently, dividend is made taxable as the income of the previous year in which it is declared. The dividend income, thus accrues as income of the previous year in which it is declared as distinct from income of the day on which it is declared. If somethi .....

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a situation in which an assessee would be entitled to say that no income by way of dividend accrued to him during the previous year. What is important is that something factual or legal should have happened during the previous year in which the dividend is declared." Likewise, in the case of New Shorrock Spg. & Mfg. Co. Ltd. (supra), facts were that the assessee company had on 25.5.72 declared its dividend for the year 1971. One Mafatlal Gagalbhai and Co. Pvt. Ltd. case (supra) holding .....

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ion came into effect from 1st April 1972. In the assessment year 1973-74, the assessee company was sought to be taxed in respect of the dividend income received by Mafatlal Gagalbhai and Co. Ltd. The contention of the assessee was that Mafatlal Gagalbhai and Co. Ltd. having ceased to exist with effect from 1st April 1972, by virtue of the orders of amalgamation, the assessee company could not be taxed for the dividend distributed in favour of Mafatlal Gagalbhai & Company. The Bombay High Cou .....

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By virtue of the decision of the High Court, such scheme was sanctioned with no variation in the effective date. Thus, the date of amalgamation which actually took effect was prior to the date on which dividend was declared and paid. In that view of the matter, we have no hesitation in holding that by virtue of such subsequent developments, the payment of dividend could no longer retain the character of dividend paid by Torrent Power Ltd since there cannot be payment of dividend by one company .....

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the case of Marshall Sons & Co. (India) Ltd. (supra), Division Bench of this Court held that such transfers would cease to be sales between two independent entities but would be treated as branch transfers. It was observed as under: "20. As already noted, the term 'sale' has been defined under section 2(23) of the Act. Upon the High Court sanctioning the scheme for amalgamation, the effective date of amalgamation would be the date mentioned in the scheme, namely, 1st June 1995. .....

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igh Court in the case of National Organic Chemicals Industries Ltd. (supra}. In the said case, this precisely was the issue presented before the High Court. A Division Bench of the High Court ruled that the Company loses its corporate personality from the date declared by the competent authority under the Companies Act. In case of amalgamation of a company, the High Court being the competent authority, when the High Court sanctions the scheme for amalgamation and declares the effective date from .....

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x Act in all material purposes are similar to the provisions arising in the Gujarat Sales Tax Act". 17. In the case of Kishenchand Chellaram (supra), the Apex Court did observe that under the Income Tax Act, liability to pay tax attaches as soon as a dividend is paid, credited or distributed or is so declared and further that once a company declares its dividend, it cannot alter the character of credit by passing subsequent resolutions. Such observations were made in the context of the fact .....

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such payment ceased to retain the character of dividend. Any other view would effectively nullify the effective date of amalgamation of companies. 18. Counsel for the Revenue, we may recall, placed reliance on the provisions of section 115-O of the Act. It is undoubtedly true that sub-section (1) of section 115-O starts with a non-obstante clause and provides that notwithstanding anything contained in any other provisions of the Act, in addition to the income chargeable to tax in case of a dome .....

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he Act thus is a charging section and pertains to collection of tax on declaration, distribution or payment of dividend by a domestic company. Subsection (3) does nothing beyond prescribing the date within which such tax must be credited to the Central Government. Neither of these two provisions or anything else contained in section 115-O of the Act, in our opinion, would change the position. In the present case, we are concerned with a situation under which after certain dividend was declared a .....

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aiming refund, a separate application was also filed which unfortunately came to be rejected by the Assessing Officer. The Assessing Officer contended that there was no provision under which such refund can be claimed. Section 237 of the Act, however, provides that if any person satisfies the Assessing Officer that the amount of tax paid by him or on his behalf or treated as paid by him or on his behalf for any assessment year exceeds the amount with which he is properly chargeable under the Act .....

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