Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Interplay between limitation for passing final assessment under section 144C(13) and section 153 is examined; the analysis applies the principle that provisions are to be read together where they are inter-dependent and overlapping, particularly regarding transfer pricing related provisions, and therefore the applicable limitation period must be determined with reference to section 144C read with section 153; consequence: final assessment orders issued beyond that combined limitation period are jurisdictionally infirm and were quashed following the precedent relied upon.
Interplay between limitation for passing final assessment under section 144C(13) and section 153 is examined; the analysis applies the principle that provisions are to be read together where they are inter-dependent and overlapping, particularly regarding transfer pricing related provisions, and therefore the applicable limitation period must be determined with reference to section 144C read with section 153; consequence: final assessment orders issued beyond that combined limitation period are jurisdictionally infirm and were quashed following the precedent relied upon.
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