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Case Name : Mrf ltd. Vs the commissioner of trade and taxes & anr. (Delhi High Court)
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MRF Ltd. Vs Commissioner of Trade and Taxes (Delhi High Court)

Pre-deposit sums which the assessee is compelled to pay to seek recourse to an appellate remedy, do not necessarily bear the stamp or character of tax, especially when it succeeds on the particular plea. That being the case, the insistence upon a procedural step, i.e. filing of a form which is purely for the purpose of  administrative convenience cannot in any manner fix the period or periods of limitation when the amounts became due on the question of  interest. The fact that the amounts were due and payable

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