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...
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
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