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 ...
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
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