Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
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 28(9A) of the Customs Act suspends the adjudication limitation period while a specified circumstance prevents determination of duty liability, with the statutory period recommencing when that circumstance ceases. Transfer of a matter to the Call Book is an administrative consequence of such deferment and does not independently create the exclusion period. Where noticees seek deferment because a connected writ petition and interim protection affect the underlying duty liability, those circumstances are directly relevant to non-determination. Noticees' own request for deferment may substantially satisfy the communication requirement. The limitation period consequently runs from dismissal of the connected writ petition, and adjudication within the ensuing unextended one-year period is timely.
Section 28(9A) of the Customs Act suspends the adjudication limitation period while a specified circumstance prevents determination of duty liability, with the statutory period recommencing when that circumstance ceases. Transfer of a matter to the Call Book is an administrative consequence of such deferment and does not independently create the exclusion period. Where noticees seek deferment because a connected writ petition and interim protection affect the underlying duty liability, those circumstances are directly relevant to non-determination. Noticees' own request for deferment may substantially satisfy the communication requirement. The limitation period consequently runs from dismissal of the connected writ petition, and adjudication within the ensuing unextended one-year period is timely.
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