Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
HC held that the 90-day time limitation for issuing show cause notice under Regulation 17(5) of Customs Brokers Licensing Regulations, 2018 is mandatory, not directory. Relying on precedent in Santon Shipping Services case, the court quashed the show cause notice and inquiry report due to non-adherence to statutory timelines. The court found that strict compliance with procedural regulations is essential, and failure to follow the prescribed 90-day limit renders the administrative actions invalid. Consequently, the writ petitions were allowed, effectively nullifying the challenged administrative documents.
HC held that the 90-day time limitation for issuing show cause notice under Regulation 17(5) of Customs Brokers Licensing Regulations, 2018 is mandatory, not directory. Relying on precedent in Santon Shipping Services case, the court quashed the show cause notice and inquiry report due to non-adherence to statutory timelines. The court found that strict compliance with procedural regulations is essential, and failure to follow the prescribed 90-day limit renders the administrative actions invalid. Consequently, the writ petitions were allowed, effectively nullifying the challenged administrative documents.
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TaxTMI 
TaxTMI 
of 4918 
