Withdrawal of obsolete FEMA circulars streamlines rules on external commercial borrowings, non-resident bond investments, and money transfer sub-agent...
Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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Territorial and subject-matter jurisdiction remains necessary for cancellation of charitable registration; designation as a Principal Commissioner or Commissioner does not itself confer authority over exemption registration. Exemption jurisdiction continues with the designated exemption authority unless lawfully transferred. Centralisation of group assessments for investigation does not establish transfer of registration jurisdiction without a transfer order, notification, or other jurisdictional instrument assigning an Assessing Officer under the relevant Central Commissioner. Notification No. 70/2014 applies only where such assignment is proved. On these principles, cancellation of registration for want of jurisdiction was quashed and the original registration restored, while the underlying allegations and retrospective-cancellation issue remained unresolved.
Territorial and subject-matter jurisdiction remains necessary for cancellation of charitable registration; designation as a Principal Commissioner or Commissioner does not itself confer authority over exemption registration. Exemption jurisdiction continues with the designated exemption authority unless lawfully transferred. Centralisation of group assessments for investigation does not establish transfer of registration jurisdiction without a transfer order, notification, or other jurisdictional instrument assigning an Assessing Officer under the relevant Central Commissioner. Notification No. 70/2014 applies only where such assignment is proved. On these principles, cancellation of registration for want of jurisdiction was quashed and the original registration restored, while the underlying allegations and retrospective-cancellation issue remained unresolved.
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