Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Jurisdiction - proper officer for issuance of SCN - DRI is proper officer or not - the show cause notice was issued by the Additional Director General, DRI under Section 28 ibid, which as per the aforesaid decision of the Hon’ble Supreme Court is without any authority of law and therefore the Appeals also deserve to be allowed on this ground itself. - AT
Jurisdiction - proper officer for issuance of SCN - DRI is proper officer or not - the show cause notice was issued by the Additional Director General, DRI under Section 28 ibid, which as per the aforesaid decision of the Hon’ble Supreme Court is without any authority of law and therefore the Appeals also deserve to be allowed on this ground itself. - AT
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