International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Levy of penalty u/s 271 (1) (c) - there is no substance in the contention of the learned counsel for the appellant in claiming that the said amendment has been applied retrospectively. Interestingly, the learned counsel for the appellant has tried to take shelter that the words "Who has not previously been assessed under this Act" which was a part of the Explanation 3 to Section 271(1)(C) prior to 01.04.2003 and omitted thereafter stating that he was an existing assessee even prior to the amendment and therefore the amended explanation was not applicable to him. However, this point has already been dealt with and clarified and needs no further elaboration. - HC
Levy of penalty u/s 271 (1) (c) - there is no substance in the contention of the learned counsel for the appellant in claiming that the said amendment has been applied retrospectively. Interestingly, the learned counsel for the appellant has tried to take shelter that the words "Who has not previously been assessed under this Act" which was a part of the Explanation 3 to Section 271(1)(C) prior to 01.04.2003 and omitted thereafter stating that he was an existing assessee even prior to the amendment and therefore the amended explanation was not applicable to him. However, this point has already been dealt with and clarified and needs no further elaboration. - HC
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