Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Change of opinion precludes reassessment of share-capital and investment transactions already examined through detailed scrutiny, where the assessee neither concealed nor withheld material; an anonymous complaint alone cannot reopen those matters. Reassessment notices converted into show-cause notices under the amended regime must be issued within the surviving limitation period after excluding the stay period and response time. Extended limitation cannot apply unless the statutory conditions are invoked and recorded, and sanction is obtained from the competent authority where the relevant period has elapsed. A notice issued beyond the surviving period is void, rendering consequential reassessment, demand and penalty actions unsustainable, subject to fresh proceedings where legally permissible.
Change of opinion precludes reassessment of share-capital and investment transactions already examined through detailed scrutiny, where the assessee neither concealed nor withheld material; an anonymous complaint alone cannot reopen those matters. Reassessment notices converted into show-cause notices under the amended regime must be issued within the surviving limitation period after excluding the stay period and response time. Extended limitation cannot apply unless the statutory conditions are invoked and recorded, and sanction is obtained from the competent authority where the relevant period has elapsed. A notice issued beyond the surviving period is void, rendering consequential reassessment, demand and penalty actions unsustainable, subject to fresh proceedings where legally permissible.
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