Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
HC dismissed the appeal, finding no substantial question of law regarding invocation of the extended five-year limitation period under Section 73(1) of Finance Act, 1994. The court upheld CESTAT's determination that the respondent's actions were based on bona fide belief rather than wilful misstatement or fraud. Though the Commissioner issued a composite show cause notice covering 2004-2009, the court declined to interfere with CESTAT's order, particularly regarding the period after the August 23, 2007 master circular, as no fraudulent intent was established to justify extending the limitation period.
HC dismissed the appeal, finding no substantial question of law regarding invocation of the extended five-year limitation period under Section 73(1) of Finance Act, 1994. The court upheld CESTAT's determination that the respondent's actions were based on bona fide belief rather than wilful misstatement or fraud. Though the Commissioner issued a composite show cause notice covering 2004-2009, the court declined to interfere with CESTAT's order, particularly regarding the period after the August 23, 2007 master circular, as no fraudulent intent was established to justify extending the limitation period.
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