Whether communication by department was in the nature of determination of the liability?


Last updated: 31 March 2023

Court :
Supreme Court of India

Brief :
The course suggested by the Counsel for the Department was acceptable to the Counsel for the Appellant. It was, therefore, suggested that the Appellant may file an affidavit of undertaking to withdraw the proceedings initiated by it before the AAR and the Department may also file an appropriate affidavit stating that it was willing to treat the communication as a show cause notice.

Citation :
COGNIZANT TECHNOLOGY SOLUTIONS INDIA PVT. LIMITED (APPELLANT) VS. DY COMMISSIONER OF INCOME TAX, LARGE TAXPAYER UNIT-1 (RESPONDENTS)

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