Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
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Assessment orders passed nearly ten years after issuance of the initial Form-H notices were held unsustainable because Rule 25 requires completion within a reasonable period, even though it prescribes no fixed outer limit. Relying on the binding precedent in Siemens Limited, the Court found that such prolonged delay in adjudication was unreasonable and unjustifiable. As the impugned assessments in all three writ petitions were made after more than ten years, they were quashed and the petitions were allowed.
Assessment orders passed nearly ten years after issuance of the initial Form-H notices were held unsustainable because Rule 25 requires completion within a reasonable period, even though it prescribes no fixed outer limit. Relying on the binding precedent in Siemens Limited, the Court found that such prolonged delay in adjudication was unreasonable and unjustifiable. As the impugned assessments in all three writ petitions were made after more than ten years, they were quashed and the petitions were allowed.
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