Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Section 129(3) requires a detention-penalty order to be passed within seven days of service of notice. The seven-day period is mandatory, not directory; an order made after that period, including one issued 28 days after notice, breaches the statutory requirement. Such delay vitiates the detention-penalty proceedings, renders the original order void ab initio and a nullity, and leaves no valid basis for an appellate order affirming the penalty.
Section 129(3) requires a detention-penalty order to be passed within seven days of service of notice. The seven-day period is mandatory, not directory; an order made after that period, including one issued 28 days after notice, breaches the statutory requirement. Such delay vitiates the detention-penalty proceedings, renders the original order void ab initio and a nullity, and leaves no valid basis for an appellate order affirming the penalty.
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