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...
Omission of the specified domestic transaction provision for related-party expenditure, without a saving clause for pending actions, treats the omitted provision as if it had never existed. Consequently, transfer-pricing cognizance taken under that omitted provision, the reference to the Transfer Pricing Officer, and consequential transfer-pricing proceedings lack validity. Applying this settled position, the Tribunal allowed the taxpayer's grounds and did not sustain the assessment founded on the impugned transfer-pricing reference.
Omission of the specified domestic transaction provision for related-party expenditure, without a saving clause for pending actions, treats the omitted provision as if it had never existed. Consequently, transfer-pricing cognizance taken under that omitted provision, the reference to the Transfer Pricing Officer, and consequential transfer-pricing proceedings lack validity. Applying this settled position, the Tribunal allowed the taxpayer's grounds and did not sustain the assessment founded on the impugned transfer-pricing reference.
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