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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HC held that Explanation to Section 149 and Explanation 4 to Section 147, introduced by Finance Act, 2012, clarify retrospective applicability for assessment years beginning on or before 1 April 2012. The use of word "any" in the explanation is not restrictive. The court noted that previous judicial interpretations in Brahm Datt and Jyoti Traders may require reconsideration by a larger bench. The matter was directed to be listed for constitution of a larger bench to comprehensively examine the legislative intent behind the amendments to income tax assessment provisions.
HC held that Explanation to Section 149 and Explanation 4 to Section 147, introduced by Finance Act, 2012, clarify retrospective applicability for assessment years beginning on or before 1 April 2012. The use of word "any" in the explanation is not restrictive. The court noted that previous judicial interpretations in Brahm Datt and Jyoti Traders may require reconsideration by a larger bench. The matter was directed to be listed for constitution of a larger bench to comprehensively examine the legislative intent behind the amendments to income tax assessment provisions.
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