Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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