AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.
A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.
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