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 ...
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An application under Section 119(2)(b) challenged refusal to permit filing a revised return beyond five years; the High Court found the taxpayer had pursued rectification within the five year window and had reasonably relied on rectification as the remedy. The court held the authority could not ignore the circular's temporal condition, treated the misdeclaration as a bona fide error without deciding revised return merits, set aside the impugned order and remitted the matter for fresh consideration of the revised return for the relevant assessment year in accordance with law.
An application under Section 119(2)(b) challenged refusal to permit filing a revised return beyond five years; the High Court found the taxpayer had pursued rectification within the five year window and had reasonably relied on rectification as the remedy. The court held the authority could not ignore the circular's temporal condition, treated the misdeclaration as a bona fide error without deciding revised return merits, set aside the impugned order and remitted the matter for fresh consideration of the revised return for the relevant assessment year in accordance with law.
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