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...
Ceasure of income tax settlement commission - restriction to the filing of the application before the Interim Board for Settlement - The Court found that the retrospective legislative changes could not negate the petitioner's vested rights to file a settlement application, particularly when such applications were made before the enactment of the Finance Act, 2021. It was held that the administrative actions and notifications that imposed additional eligibility criteria, not rooted in the Act, were invalid. - The Court quashed the contested notice and notification, directing that the petitioner's application be considered and disposed of in accordance with the law.
Ceasure of income tax settlement commission - restriction to the filing of the application before the Interim Board for Settlement - The Court found that the retrospective legislative changes could not negate the petitioner's vested rights to file a settlement application, particularly when such applications were made before the enactment of the Finance Act, 2021. It was held that the administrative actions and notifications that imposed additional eligibility criteria, not rooted in the Act, were invalid. - The Court quashed the contested notice and notification, directing that the petitioner's application be considered and disposed of in accordance with the law.
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