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 ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.
Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
