| Case ID |
dfaa620d-19e2-4bfb-9186-e603667605b7 |
| Body |
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| Case Number |
WRIT PETITION Nos. 914 OF 1963 |
| Decision Date |
Jan 18, 1967 |
| Hearing Date |
|
| Decision |
The petition was dismissed, affirming the revenue's position that the assessee was entitled to interest only on the refund amount for the period specifically covered by the reference. The court clarified that while the reference related to a particular assessment year, any adjustments or claims for interest on refunds for other periods could not be justified based on the principles established in the reference. The court upheld that refunds for accounting periods outside the reference were not a direct result of the reference itself, thereby validating the revenue's stance on interest entitlement. |
| Summary |
In the case of S.V.P.N. Sithambara Nadar Sons v. Commissioner of Income Tax, the Madras High Court dealt with the interpretation of tax provisions related to income tax and excess profits tax. The primary issue revolved around the entitlement of the petitioner to interest on tax refunds that arose from a reference to the High Court concerning a specific assessment year. The court ruled that the interest was only applicable to the refund amount for that assessment year, dismissing claims for interest on refunds for other accounting periods. This case emphasizes the rigid interpretation of tax laws regarding assessment years and the conditions under which refunds and interest are applicable, making it a significant reference point in tax law jurisprudence. Keywords such as 'Income Tax Refunds', 'Tax Law', 'Madras High Court', and 'Excess Profits Tax' make this case relevant for legal practitioners and tax professionals seeking to understand the nuances of tax assessments and refunds. |
| Court |
Madras High Court
|
| Entities Involved |
Not available
|
| Judges |
Veeraswami, J.,
Ramaprasada Rao, J.
|
| Lawyers |
K.R. Ramamani,
Subbaraya Iyer,
Seturaman,
Padmanabhan,
V. Balasubrahmanyan
|
| Petitioners |
S.V.P.N. Sithambara Nadar Sons
|
| Respondents |
Commissioner of Income Tax
|
| Citations |
1968 SLD 273,
(1968) 67 ITR 45
|
| Other Citations |
Not available
|
| Laws Involved |
Income-tax Act, 1961,
Indian Income-tax Act, 1922,
Excess Profits Tax Act, 1940
|
| Sections |
265,
66(7),
2(1)
|