Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
CESTAT held that issuance of a Discharge Certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 conclusively settles the entire liability of duty, interest and penalty, including redemption fine linked to confiscation for the same matter and period. Confiscation under Rule 25 of the Central Excise Rules and the corresponding option to redeem on payment of fine were treated as penalties in rem arising from the same investigation and thus covered by the Scheme. Consequently, upon grant of the Discharge Certificate, no further liability, including redemption fine, survived. The Commissioner (Appeals)' order dated 28.03.2024 was set aside and both appeals were allowed.
CESTAT held that issuance of a Discharge Certificate under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 conclusively settles the entire liability of duty, interest and penalty, including redemption fine linked to confiscation for the same matter and period. Confiscation under Rule 25 of the Central Excise Rules and the corresponding option to redeem on payment of fine were treated as penalties in rem arising from the same investigation and thus covered by the Scheme. Consequently, upon grant of the Discharge Certificate, no further liability, including redemption fine, survived. The Commissioner (Appeals)' order dated 28.03.2024 was set aside and both appeals were allowed.
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TaxTMI 
TaxTMI 
