Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
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...
Proof of service and acknowledgment of statutory summons are necessary to support an allegation of deliberate or wilful non-compliance during an investigation. Mere issuance of summons, without material establishing that the person concerned received and acknowledged them, does not establish intentional disobedience or evasion of appearance. On those facts, declining cognizance of the complaint was treated as free from jurisdictional error. Fresh summons may be issued where legally permissible, provided they are duly served and proof of service is maintained. No conclusion follows on the merits of the investigation or on any underlying liability or offence.
Proof of service and acknowledgment of statutory summons are necessary to support an allegation of deliberate or wilful non-compliance during an investigation. Mere issuance of summons, without material establishing that the person concerned received and acknowledged them, does not establish intentional disobedience or evasion of appearance. On those facts, declining cognizance of the complaint was treated as free from jurisdictional error. Fresh summons may be issued where legally permissible, provided they are duly served and proof of service is maintained. No conclusion follows on the merits of the investigation or on any underlying liability or offence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
