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TMI Blog2021 (2) TMI 800X X X X Extracts X X X X X X X X Extracts X X X X ..... ion for release of tax refunds but the said grievance was closed stating that separate applications are required to be filed for each of the assessment year. The petitioner again filed separate grievance letters seeking same relief and vide order dated 06.07.2020, CPGRAM ordered refund amounting to INR 3,50,35,301 instead of INR 8,20,49,885 (excluding interest). The huge amount of refund, despite having been determined by the AO vide order dated 04.12.2018 passed under Section 154 read with Section 143(3) of the Act, have subsequently been reduced vide the CPGRAM disposal order dated 06.07.2020, without giving any reasons/intimation to the petitioner. Even the amount of refund agreed to be paid to the petitioner vide CPGRAM disposal order d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... roducts and services. The petitioner is a tax resident of USA and is duly assessed to tax in USA, while abiding with the tax laws of the various countries worldwide within which it operates. The petitioner filed return of income for the assessment year 2003-04 on 02.12.2003 declaring "Nil" income. The said return was subsequently revised on 01.12.2004 to claim correct amount of TDS credit of INR 8.31 crore as against the TDS credit of INR 1.52 crore claimed in the original return. Thereafter, the income of the petitioner was assessed by the Assessing Officer vide assessment order dated 22.03.2006 at INR 45,76,48,446 as against Nil income returned, alleging that the petitioner had a Permanent Establishment (for short' "PE& ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e CIT directed to AO to process the refund online and refused to approve manual refund. Then the petitioner started following up with the AO for online processing, but petitioner was informed verbally that refunds were processed by AO seeking approval of Additional Commissioner of Income Tax and refund is now pending with Central Processing Centre for its release, but till date no refund was actually released by the CPC. On 22.01.2020, the petitioner filed its grievance with the online portal requesting to direct the department to take immediate action for release of tax refunds but the said grievance was closed stating that separate applications are required to be filed for each of the assessment year. The petitioner again filed separate g ..... X X X X Extracts X X X X X X X X Extracts X X X X
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