International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Limitation for passing a final assessment under section 144C(13) must be assessed in light of the interplay between section 144C and section 153: the tribunal applied preceding decisions holding the two provisions to be mutually inclusive and overlapping, so the limitation period for a 144C(13) assessment is to be governed with reference to section 153 read with section 144C. Applying that principle, the impugned final assessment under section 143(3) read with 144C(13) was held timebarred and quashed. Parties are granted liberty to revive the appeal on merits if the pending Supreme Court larger bench decision requires modification.
Limitation for passing a final assessment under section 144C(13) must be assessed in light of the interplay between section 144C and section 153: the tribunal applied preceding decisions holding the two provisions to be mutually inclusive and overlapping, so the limitation period for a 144C(13) assessment is to be governed with reference to section 153 read with section 144C. Applying that principle, the impugned final assessment under section 143(3) read with 144C(13) was held timebarred and quashed. Parties are granted liberty to revive the appeal on merits if the pending Supreme Court larger bench decision requires modification.
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