Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
HC affirmed penalty proceedings under s271D were time-barred due to procedural delays. Initial reference by ITO on 16.11.2016 was followed by Show Cause Notice from Additional CIT only on 10.11.2017, with final penalty order issued on 22.02.2018. This exceeded statutory limitation period from reference date. Revenue provided no justification for delayed issuance of show cause notice. Court rejected Revenue's reliance on TAM TAM precedent as fact-specific, distinguishing it from present case. Tribunal's order upheld, finding proceedings initiated beyond limitation period invalid. Questions of law resolved in assessee's favor, invalidating penalty imposed for s269SS violations.
HC affirmed penalty proceedings under s271D were time-barred due to procedural delays. Initial reference by ITO on 16.11.2016 was followed by Show Cause Notice from Additional CIT only on 10.11.2017, with final penalty order issued on 22.02.2018. This exceeded statutory limitation period from reference date. Revenue provided no justification for delayed issuance of show cause notice. Court rejected Revenue's reliance on TAM TAM precedent as fact-specific, distinguishing it from present case. Tribunal's order upheld, finding proceedings initiated beyond limitation period invalid. Questions of law resolved in assessee's favor, invalidating penalty imposed for s269SS violations.
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