AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.
Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.
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