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    Transfer pricing limitation and DTAA relief: time-bar finding reversed, merits remanded, fresh treaty claim not admitted.
    Year of taxability for unexplained share investment must match the purchase year, not a later assessment year.
    Aggregated TNMM and CSR donation deduction principles shape transfer pricing relief and section 80G allowance
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      VAT / Sales Tax

      Section 4A of the 1957 AP Sales Tax Act was treated as...

      Inter-State sales proof and assessment jurisdiction upheld; limitation, cross-examination, and penalty objections were rejected.

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      VAT / Sales TaxMay 13, 2026Case LawsAT
      Section 4A of the 1957 AP Sales Tax Act was treated as empowering a superior officer to exercise assessment powers without a separate jurisdictional order, so the Deputy Commissioner's assessment was upheld. The extended limitation under section 14(3) applied because the dealer produced accounts and related material after inspection, making the assessment timely. The dealer failed to discharge the section 6A burden to prove stock transfer or agency movement in the prescribed manner, so the transactions were treated as inter-State sales and the natural justice objection based on denial of cross-examination failed. Claims of double turnover addition and sales return deductions were rejected for want of proof, and penalty under the CST regime was sustained through the State penalty provision.

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      ActsIncome Tax