Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Section 74 tax determinations based on suppression of facts require service of a statutory show cause notice and consideration of the taxpayer's representation. The notice must specify the demand, foundational facts and necessary particulars so the taxpayer can respond effectively. GST DRC forms or other communications cannot substitute for the statutory notice. Determining a demand without serving such notice denies the taxpayer knowledge of the allegations and an effective opportunity of representation, vitiating the proceedings; the first appellate order was set aside and the appeal allowed.
Section 74 tax determinations based on suppression of facts require service of a statutory show cause notice and consideration of the taxpayer's representation. The notice must specify the demand, foundational facts and necessary particulars so the taxpayer can respond effectively. GST DRC forms or other communications cannot substitute for the statutory notice. Determining a demand without serving such notice denies the taxpayer knowledge of the allegations and an effective opportunity of representation, vitiating the proceedings; the first appellate order was set aside and the appeal allowed.
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