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Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
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Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Proceedings under section 201(1) were held time-barred because earlier TDS communications were only information requests and did not amount to initiation; the first valid show-cause notice was issued in 2010. The Court accepted that the proviso to section 201(3), allowing completion up to 31 March 2011, applied only to already pending proceedings and could not revive a fresh initiation after limitation had expired. As the period for commencing action had run out for the assessment years concerned, no substantial question of law arose and the Revenue's challenge failed. The appeal was dismissed.
Proceedings under section 201(1) were held time-barred because earlier TDS communications were only information requests and did not amount to initiation; the first valid show-cause notice was issued in 2010. The Court accepted that the proviso to section 201(3), allowing completion up to 31 March 2011, applied only to already pending proceedings and could not revive a fresh initiation after limitation had expired. As the period for commencing action had run out for the assessment years concerned, no substantial question of law arose and the Revenue's challenge failed. The appeal was dismissed.
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