Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Territorial jurisdiction under Article 226 depends on where the material facts forming the cause of action arise. Seizure of imported stainless-steel coils and consideration of their provisional release occurred at ICD Dadri under the Commissioner of Customs, Noida; Delhi-based customs, DRI or CBIC headquarters did not create a territorial nexus. Objections concerning classification, the Chartered Engineer's certificate and CBIC policy were to be considered by the Noida Commissioner. Forum conveniens cannot cure a complete absence of territorial jurisdiction. The writ petition was dismissed, with liberty to seek relief before the appropriate forum.
Territorial jurisdiction under Article 226 depends on where the material facts forming the cause of action arise. Seizure of imported stainless-steel coils and consideration of their provisional release occurred at ICD Dadri under the Commissioner of Customs, Noida; Delhi-based customs, DRI or CBIC headquarters did not create a territorial nexus. Objections concerning classification, the Chartered Engineer's certificate and CBIC policy were to be considered by the Noida Commissioner. Forum conveniens cannot cure a complete absence of territorial jurisdiction. The writ petition was dismissed, with liberty to seek relief before the appropriate forum.
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TaxTMI 
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