Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
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