Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
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Pan-India jurisdiction of specified Additional and Joint Commissioners to adjudicate composite DGGI show cause notices rests on the governing notifications. A circular may operationalise that jurisdiction by selecting a common adjudicating authority from officers already competent, but cannot itself confer or enlarge jurisdiction. Selection based on the highest-demand criterion is objective, uniformly applicable and rationally connected to consistent single adjudication, rather than impermissible sub-delegation or arbitrary classification. The notified appellate forum corresponds to the Commissionerate of the common authority. Once a jurisdictional challenge fails, challenges on merits, evidence and natural justice must proceed through the statutory appeal, with merits remaining open.
Pan-India jurisdiction of specified Additional and Joint Commissioners to adjudicate composite DGGI show cause notices rests on the governing notifications. A circular may operationalise that jurisdiction by selecting a common adjudicating authority from officers already competent, but cannot itself confer or enlarge jurisdiction. Selection based on the highest-demand criterion is objective, uniformly applicable and rationally connected to consistent single adjudication, rather than impermissible sub-delegation or arbitrary classification. The notified appellate forum corresponds to the Commissionerate of the common authority. Once a jurisdictional challenge fails, challenges on merits, evidence and natural justice must proceed through the statutory appeal, with merits remaining open.
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