“Section 244(1)”

The Revenue is bound by the rule of consistency and cannot adopt a divergent position in a subsequent assessment year unless there is a change in facts or law.

The Department has a moral and legal obligation to refund excess tax collected from taxpayers, along with interest. An assessee is entitled to interest on the amount of taxes refunded, including interest on interest, as per Section 244A of the Income-tax Act.

Under Section 244A, the "amount due" for a refund includes both the principal tax and the interest accrued thereon up to the date the refund is granted. If the revenue fails to pay the full amount of refund, it is liable to pay further interest on the outstanding balance of this total refund, which does not constitute "interest on interest".

Where the Assessing Officer has no option but to resort to the provisions of Rule 8D read with Section 14A, the disallowance can be made under Section 14A.

Exchange fluctuation losses incurred on foreign currency loans can be claimed as a revenue expenditure if not covered by specific provisions like Section 43A and are in accordance with generally accepted accounting practices.

Findings in earlier assessment years are not conclusive and facts can be reconsidered in later years, leading to different findings.

Interest expenditure incurred on loans for investment in a subsidiary is allowable as a business deduction under Section 36(1)(iii) if the investment is made for the purpose of business.

Explanation 5A to section 271(1) is attracted when incriminating evidence is found during a search and undisclosed income arising from that evidence is accepted by the assessee.