Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Determination of the limitation period for passing final transfer-pricing assessment under section 144C(13) was contested with respect to its interplay with section 153. The tribunal noted higher-court precedent holding the two provisions are interdependent and limitation must be determined with reference to section 144C read with section 153; applying that approach, the tribunal found final assessment orders were passed beyond the applicable limitation period and therefore lacked jurisdiction. Consequently, the impugned final assessment orders were quashed for being time-barred.
Determination of the limitation period for passing final transfer-pricing assessment under section 144C(13) was contested with respect to its interplay with section 153. The tribunal noted higher-court precedent holding the two provisions are interdependent and limitation must be determined with reference to section 144C read with section 153; applying that approach, the tribunal found final assessment orders were passed beyond the applicable limitation period and therefore lacked jurisdiction. Consequently, the impugned final assessment orders were quashed for being time-barred.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
