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Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
HC held that once a valid declaration under SVLDRS was filed and a Discharge Certificate issued, all tax dues for the relevant period stood settled, absent any allegation of falsity, misstatement or suppression. The subsequent demand of interest and penalty by letters and show cause notices, despite such discharge, was held to be ex facie contrary to Sections 124, 126, 128 and 129 of the Finance Act, 2019 and violative of Article 265. HC directed the revenue authority to treat the petitioner's declaration under the "investigation" category and extend the consequential statutory reliefs. The impugned demands were quashed and the petition allowed.
HC held that once a valid declaration under SVLDRS was filed and a Discharge Certificate issued, all tax dues for the relevant period stood settled, absent any allegation of falsity, misstatement or suppression. The subsequent demand of interest and penalty by letters and show cause notices, despite such discharge, was held to be ex facie contrary to Sections 124, 126, 128 and 129 of the Finance Act, 2019 and violative of Article 265. HC directed the revenue authority to treat the petitioner's declaration under the "investigation" category and extend the consequential statutory reliefs. The impugned demands were quashed and the petition allowed.
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