Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
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