Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsustainable. Purchases supported by commercial records and made for business purposes may qualify as commercially expedient expenditure despite expiry of a distributorship agreement.
Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsustainable. Purchases supported by commercial records and made for business purposes may qualify as commercially expedient expenditure despite expiry of a distributorship agreement.
Note: It is a system-generated summary and is for quick reference only.
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