Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.
Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.
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TaxTMI 
TaxTMI 
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