Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Territorial Jurisdiction - Levy of sales tax - it argued that the KST Act does not extend to territorial waters of India situated adjacent to the landmass of the State of Karnataka - the agreement has been admittedly signed in Mangalore, and the vessel is used in the territorial waters - It makes no difference as the situs of the deemed sale is in Mangalore. Thus, the liability to pay tax under the Act cannot be countenanced.
Territorial Jurisdiction - Levy of sales tax - it argued that the KST Act does not extend to territorial waters of India situated adjacent to the landmass of the State of Karnataka - the agreement has been admittedly signed in Mangalore, and the vessel is used in the territorial waters - It makes no difference as the situs of the deemed sale is in Mangalore. Thus, the liability to pay tax under the Act cannot be countenanced.
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