Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
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