Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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The dispute concerned whether the limitation for passing a final assessment under the transfer pricing assessment procedure must be measured solely by the timeline in the specific transfer pricing provision or by reference to both that provision and the general assessment limitation provision; the tribunal concluded that the provisions are mutually inclusive and overlapping, and limitation must be determined with reference to both provisions, resulting in final assessment orders issued beyond the combined limitation period being without jurisdiction and quashed for the specified assessment years.
The dispute concerned whether the limitation for passing a final assessment under the transfer pricing assessment procedure must be measured solely by the timeline in the specific transfer pricing provision or by reference to both that provision and the general assessment limitation provision; the tribunal concluded that the provisions are mutually inclusive and overlapping, and limitation must be determined with reference to both provisions, resulting in final assessment orders issued beyond the combined limitation period being without jurisdiction and quashed for the specified assessment years.
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