Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
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