Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Reopening based on audit objections and issues already examined in scrutiny assessment was treated as a mere change of opinion, because the Assessing Officer had raised specific queries in the original proceedings and the assessee had disclosed full particulars. The reassessment was held invalid on depreciation claims for computers, plant and machinery, goodwill, CSR-linked deduction under Chapter VI-A, and excess discount provision, since each issue had been considered earlier or lacked a live nexus with any new material. The recorded reasons were also found vague on excess depreciation and contrary to the statutory scheme on additional depreciation and goodwill. On that basis, the notice under section 148 and the order rejecting objections were quashed.
Reopening based on audit objections and issues already examined in scrutiny assessment was treated as a mere change of opinion, because the Assessing Officer had raised specific queries in the original proceedings and the assessee had disclosed full particulars. The reassessment was held invalid on depreciation claims for computers, plant and machinery, goodwill, CSR-linked deduction under Chapter VI-A, and excess discount provision, since each issue had been considered earlier or lacked a live nexus with any new material. The recorded reasons were also found vague on excess depreciation and contrary to the statutory scheme on additional depreciation and goodwill. On that basis, the notice under section 148 and the order rejecting objections were quashed.
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