Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Section 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.
Section 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.
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TaxTMI 
TaxTMI 
of 4888 
