Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Tribunal extending stay of demand beyond 365 days u/s 254(2A) is permissible if delay in disposing appeal is not attributable to assessee. Delhi High Court in Pepsi Foods (P) Ltd. struck down proviso prohibiting extension beyond 365 days even if delay not caused by assessee. Supreme Court upheld Delhi High Court's decision. Bombay High Court in Fulford (India) Ltd. refused to entertain Revenue's appeals challenging Tribunal orders granting extension, in line with Pepsi Foods.
Tribunal extending stay of demand beyond 365 days u/s 254(2A) is permissible if delay in disposing appeal is not attributable to assessee. Delhi High Court in Pepsi Foods (P) Ltd. struck down proviso prohibiting extension beyond 365 days even if delay not caused by assessee. Supreme Court upheld Delhi High Court's decision. Bombay High Court in Fulford (India) Ltd. refused to entertain Revenue's appeals challenging Tribunal orders granting extension, in line with Pepsi Foods.
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