Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT adjudicated a tax assessment reopening dispute, holding that revenue's attempt to extend limitation period through reminder communications was invalid. The tribunal rejected revenue's contention regarding 14-day response timeline, finding it inconsistent with judicial precedent. The assessment order was quashed as the section 148A(d) order and section 148 notice were issued beyond the prescribed limitation period. The tribunal determined that without a valid notice, the assessment order dated 30.05.2023 could not be sustained. The decision was rendered in favor of the assessee, effectively nullifying the tax department's reassessment proceedings due to procedural non-compliance with statutory timelines.
ITAT adjudicated a tax assessment reopening dispute, holding that revenue's attempt to extend limitation period through reminder communications was invalid. The tribunal rejected revenue's contention regarding 14-day response timeline, finding it inconsistent with judicial precedent. The assessment order was quashed as the section 148A(d) order and section 148 notice were issued beyond the prescribed limitation period. The tribunal determined that without a valid notice, the assessment order dated 30.05.2023 could not be sustained. The decision was rendered in favor of the assessee, effectively nullifying the tax department's reassessment proceedings due to procedural non-compliance with statutory timelines.
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