Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Finality of tax liability was central to the closure of criminal prosecution. The liability dispute had not become final when the Trial Court closed the prosecution; the tax demand was determined, accepted and complied with only afterwards. Closure on the premise that the liability had already been fully satisfied therefore failed to account for material subsequent developments. The closure order was set aside, and the matter was remanded to the Trial Court for fresh consideration in accordance with law, without any view on the merits of the criminal prosecution.
Finality of tax liability was central to the closure of criminal prosecution. The liability dispute had not become final when the Trial Court closed the prosecution; the tax demand was determined, accepted and complied with only afterwards. Closure on the premise that the liability had already been fully satisfied therefore failed to account for material subsequent developments. The closure order was set aside, and the matter was remanded to the Trial Court for fresh consideration in accordance with law, without any view on the merits of the criminal prosecution.
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