Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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Full and true disclosure under Section 245C(1) must extend to the entire settlement application, including the manner in which undisclosed income was derived and supporting particulars. A voluntary disclosure does not remove this statutory requirement; failure to substantiate a disputed income component can invalidate the settlement application as a whole, rather than permit piecemeal consideration. The notes further state that the Settlement Commission must examine the application as filed and cannot recharacterise income disclosed as business income under Section 69B or apply Section 115BBE. Any alternative assessment and consequential tax treatment must arise in regular assessment proceedings before the Assessing Officer.
Full and true disclosure under Section 245C(1) must extend to the entire settlement application, including the manner in which undisclosed income was derived and supporting particulars. A voluntary disclosure does not remove this statutory requirement; failure to substantiate a disputed income component can invalidate the settlement application as a whole, rather than permit piecemeal consideration. The notes further state that the Settlement Commission must examine the application as filed and cannot recharacterise income disclosed as business income under Section 69B or apply Section 115BBE. Any alternative assessment and consequential tax treatment must arise in regular assessment proceedings before the Assessing Officer.
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