Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
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