Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
In fraud assessments, the six-month period for issuing a show cause notice before the order-in-original was treated as directory, not mandatory, because the statute prescribed no consequence for breach; the challenge therefore turned on prejudice, and none was shown where multiple notices, replies, and personal hearings were granted and the assessment was passed within limitation. The writ court also declined to bypass the statutory remedy, noting that the Supreme Court had already left the assessee to pursue the appellate forum with all contentions available, including alleged prejudice from missing files; the writ petition was dismissed with liberty to invoke that remedy.
In fraud assessments, the six-month period for issuing a show cause notice before the order-in-original was treated as directory, not mandatory, because the statute prescribed no consequence for breach; the challenge therefore turned on prejudice, and none was shown where multiple notices, replies, and personal hearings were granted and the assessment was passed within limitation. The writ court also declined to bypass the statutory remedy, noting that the Supreme Court had already left the assessee to pursue the appellate forum with all contentions available, including alleged prejudice from missing files; the writ petition was dismissed with liberty to invoke that remedy.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
