Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
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Principles of natural justice and protection against arbitrary administrative action form the central subject: the note examines undue haste by a tax authority as violative of Article 14, emphasising that hearings must be meaningful and capable of altering outcomes. It addresses rectification under section 161 and adjudication under section 74 of the GST Act, and treats limitation as a mixed question of law and fact; the operative consequence urged is fresh consideration of rectification, limitation and adjudication after affording a proper opportunity of hearing.
Principles of natural justice and protection against arbitrary administrative action form the central subject: the note examines undue haste by a tax authority as violative of Article 14, emphasising that hearings must be meaningful and capable of altering outcomes. It addresses rectification under section 161 and adjudication under section 74 of the GST Act, and treats limitation as a mixed question of law and fact; the operative consequence urged is fresh consideration of rectification, limitation and adjudication after affording a proper opportunity of hearing.
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