Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.
Customs show cause notice adjudication must ordinarily be completed within one year under the unamended framework, unless the officer demonstrates that completion was impracticable. The phrase "where it is possible to do so" does not allow proceedings to remain pending indefinitely or for an unreasonable period. Limitation affects jurisdiction, rendering an order passed beyond the applicable period invalid. Although a procedural amendment may generally operate retrospectively, it cannot revive a stale claim; adjudication must also satisfy any extended period available under the amended regime. Unsupported placement in the Call Book does not justify prolonged delay. Unreasonable and arbitrary delay in adjudication violates Article 14 and can invalidate the resulting customs order.
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