Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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