Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Prayer for a direction extending the validity period of Duty Credit Certificate by a period of 15 years - permit use of the Duty Credit Certificate to defray I.G.S.T and G.S.T Compensation Cess - The High Court held that, the notifications and handbook provisions were within the legal authority and did not violate the petitioner's constitutional rights. - The court acknowledged the petitioner's entitlement under the TPS but noted the procedural and legal complexities that affected the utilization of duty credits. It highlighted that the entitlements were subject to the conditions and limitations set forth in the relevant notifications and handbook provisions. - Thus, the Court cannot come to the aid of the petitioner by granting the relief of extending time by 15 years as the same is not based on any concomitant right.
Prayer for a direction extending the validity period of Duty Credit Certificate by a period of 15 years - permit use of the Duty Credit Certificate to defray I.G.S.T and G.S.T Compensation Cess - The High Court held that, the notifications and handbook provisions were within the legal authority and did not violate the petitioner's constitutional rights. - The court acknowledged the petitioner's entitlement under the TPS but noted the procedural and legal complexities that affected the utilization of duty credits. It highlighted that the entitlements were subject to the conditions and limitations set forth in the relevant notifications and handbook provisions. - Thus, the Court cannot come to the aid of the petitioner by granting the relief of extending time by 15 years as the same is not based on any concomitant right.
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