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...
The vested right of appeal arises when the lis is instituted, and a later amendment imposing a fresh pre-deposit obligation does not apply to pending proceedings without clear legislative intent. Where a penalty-only appeal arose from a show-cause notice issued before the amended proviso took effect, the post-amendment pre-deposit requirement could not be imposed. The Registry's objection was set aside, the appeal was admitted without pre-deposit, and jurisdictional and merits issues remained open for final hearing.
The vested right of appeal arises when the lis is instituted, and a later amendment imposing a fresh pre-deposit obligation does not apply to pending proceedings without clear legislative intent. Where a penalty-only appeal arose from a show-cause notice issued before the amended proviso took effect, the post-amendment pre-deposit requirement could not be imposed. The Registry's objection was set aside, the appeal was admitted without pre-deposit, and jurisdictional and merits issues remained open for final hearing.
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TaxTMI 
TaxTMI 
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