Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
Office memorandum clarifies the procedure when a taxpayer's MAP application under Rule 44G is successfully resolved while an income tax appeal is pending before the Commissioner of Income Tax (Appeals). Following mutual agreement, the taxpayer must accept or reject the resolution and provide proof of appeal withdrawal. Since no explicit process existed for withdrawal at the CIT(A) stage, the memorandum directs CIT(A) offices to issue an intimation confirming acceptance of withdrawal of the appeal or specific grounds covered by the MAP resolution. This intimation will constitute valid proof of withdrawal for purposes of Rule 44G(8).
Office memorandum clarifies the procedure when a taxpayer's MAP application under Rule 44G is successfully resolved while an income tax appeal is pending before the Commissioner of Income Tax (Appeals). Following mutual agreement, the taxpayer must accept or reject the resolution and provide proof of appeal withdrawal. Since no explicit process existed for withdrawal at the CIT(A) stage, the memorandum directs CIT(A) offices to issue an intimation confirming acceptance of withdrawal of the appeal or specific grounds covered by the MAP resolution. This intimation will constitute valid proof of withdrawal for purposes of Rule 44G(8).
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