Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Reasonable time limit for issuing notice u/s 201(1)/201(1A) is 4 years, as held in GE India Technology Centre and Mahindra & Mahindra Ltd. judgments. Where notice is issued beyond 4 years, it is barred by limitation u/s 201(1). In the present case, orders are beyond 4 years from the end of the financial year, hence unsustainable and quashed. The entire proceeding arose from a belated and unsustainable survey u/s 133A(2A) conducted on 09/12/2019, which is quashed. Non-resident income is clearly time-barred, while resident income transaction did not crystallize. Assessee's appeal allowed.
Reasonable time limit for issuing notice u/s 201(1)/201(1A) is 4 years, as held in GE India Technology Centre and Mahindra & Mahindra Ltd. judgments. Where notice is issued beyond 4 years, it is barred by limitation u/s 201(1). In the present case, orders are beyond 4 years from the end of the financial year, hence unsustainable and quashed. The entire proceeding arose from a belated and unsustainable survey u/s 133A(2A) conducted on 09/12/2019, which is quashed. Non-resident income is clearly time-barred, while resident income transaction did not crystallize. Assessee's appeal allowed.
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