Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
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