Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
In writ proceedings, a taxpayer who received a show cause notice alleging wilful suppression and invoking Section 74, but filed no reply, made payment without protest, and accepted before the adjudicating authority that tax, interest and penalty would be paid, was held estopped from taking a contrary stand later. The Court treated the recorded admission and unchallenged adjudication note as decisive, and held that prior voluntary payment after audit detection did not by itself defeat Section 74 where the allegation of suppression remained uncontested. On that basis, no interference under Article 226 was made and the writ challenge failed.
In writ proceedings, a taxpayer who received a show cause notice alleging wilful suppression and invoking Section 74, but filed no reply, made payment without protest, and accepted before the adjudicating authority that tax, interest and penalty would be paid, was held estopped from taking a contrary stand later. The Court treated the recorded admission and unchallenged adjudication note as decisive, and held that prior voluntary payment after audit detection did not by itself defeat Section 74 where the allegation of suppression remained uncontested. On that basis, no interference under Article 226 was made and the writ challenge failed.
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