International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
A draft assessment order is required before a prejudicial variation is made to an eligible non-resident individual, preserving the statutory opportunity to seek Dispute Resolution Panel review; the article reports that bypassing this requirement rendered the final assessment jurisdictionally invalid. It further states that best judgment assessment requires actual statutory non-compliance, which was absent where a verified return and supporting responses were furnished. Assessment of an accepted non-resident must be completed by the International Taxation officer, and faceless proceedings did not cure the Gurgaon officer's lack of jurisdiction. Duplicate Form 26AS reporting could not justify an addition where the property deed, bank records and remittance source explained the actual purchase. The reported assessment, demand and penalty notice were quashed without remand.
A draft assessment order is required before a prejudicial variation is made to an eligible non-resident individual, preserving the statutory opportunity to seek Dispute Resolution Panel review; the article reports that bypassing this requirement rendered the final assessment jurisdictionally invalid. It further states that best judgment assessment requires actual statutory non-compliance, which was absent where a verified return and supporting responses were furnished. Assessment of an accepted non-resident must be completed by the International Taxation officer, and faceless proceedings did not cure the Gurgaon officer's lack of jurisdiction. Duplicate Form 26AS reporting could not justify an addition where the property deed, bank records and remittance source explained the actual purchase. The reported assessment, demand and penalty notice were quashed without remand.
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