Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Statutory pre-deposit for an appeal against a penalty order does not apply under the proviso where the original order imposed a composite liability for tax, interest and penalty. Payment of the tax and interest components does not convert that original composite order into an order demanding penalty alone. A later recovery order confined to penalty likewise does not alter the character of the original order. Accordingly, rejection of the appeal for failure to deposit ten per cent of the penalty was set aside and the appeal was restored for adjudication on merits.
Statutory pre-deposit for an appeal against a penalty order does not apply under the proviso where the original order imposed a composite liability for tax, interest and penalty. Payment of the tax and interest components does not convert that original composite order into an order demanding penalty alone. A later recovery order confined to penalty likewise does not alter the character of the original order. Accordingly, rejection of the appeal for failure to deposit ten per cent of the penalty was set aside and the appeal was restored for adjudication on merits.
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