International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Invocation of the extended limitation period under Section 73(1) of the Finance Act, 1994 was held unsustainable because the show-cause notice did not plead or disclose the requisite jurisdictional ingredients (such as suppression or wilful misstatement) and lacked supporting material. Limitation was treated as a jurisdictional fact, requiring satisfaction of both factual and legal elements before extended limitation could be assumed. Since the notice was cryptic, non-speaking, and unreasoned, the authority could not lawfully assume jurisdiction by invoking Section 73(1). Consequently, the show-cause notice and all proceedings pursuant to it were quashed, and the petition was allowed. - HC
Invocation of the extended limitation period under Section 73(1) of the Finance Act, 1994 was held unsustainable because the show-cause notice did not plead or disclose the requisite jurisdictional ingredients (such as suppression or wilful misstatement) and lacked supporting material. Limitation was treated as a jurisdictional fact, requiring satisfaction of both factual and legal elements before extended limitation could be assumed. Since the notice was cryptic, non-speaking, and unreasoned, the authority could not lawfully assume jurisdiction by invoking Section 73(1). Consequently, the show-cause notice and all proceedings pursuant to it were quashed, and the petition was allowed. - HC
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