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...
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
