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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The High Court examined whether the respondents had sufficient material to transfer the petitioners' case from Coimbatore to the Central Circle in Kolkata. The petitioners objected to the transfer, citing age, litigation costs, their registered office in Coimbatore, and document availability there. However, the court found that the petitioners had a place of business in Kolkata, and the Kolkata Circle had seized incriminating materials linking the petitioners to lottery business operations within its jurisdiction. The show cause notice was issued, and after considering the petitioners' replies and non-appearance for personal hearing, the case was transferred to the Central Circle in Kolkata under relevant provisions of the Income Tax Act. The court held that when incriminating materials are found at the place of business, it is appropriate to transfer the assessment to the Circle where the materials were seized, irrespective of the registered office location. Section 127 empowers such transfers, and the respondents rightly transferred the case to Kolkata as the officers there had the relevant materials.
The High Court examined whether the respondents had sufficient material to transfer the petitioners' case from Coimbatore to the Central Circle in Kolkata. The petitioners objected to the transfer, citing age, litigation costs, their registered office in Coimbatore, and document availability there. However, the court found that the petitioners had a place of business in Kolkata, and the Kolkata Circle had seized incriminating materials linking the petitioners to lottery business operations within its jurisdiction. The show cause notice was issued, and after considering the petitioners' replies and non-appearance for personal hearing, the case was transferred to the Central Circle in Kolkata under relevant provisions of the Income Tax Act. The court held that when incriminating materials are found at the place of business, it is appropriate to transfer the assessment to the Circle where the materials were seized, irrespective of the registered office location. Section 127 empowers such transfers, and the respondents rightly transferred the case to Kolkata as the officers there had the relevant materials.
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