Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Reopening of assessment was examined on the basis of incorrect facts, borrowed satisfaction and an uncorroborated search statement. The Tribunal noted that the recorded reasons wrongly stated that share premium had been received and even identified entities that had not been allotted shares, showing non-application of mind by the Assessing Officer. It further held that reopening could not rest only on the director's statement without supporting material, consistent with CBDT instructions discouraging additions based solely on confession. On that basis, the notice for reopening and the consequential reassessment were quashed, and the jurisdictional challenge was allowed.
Reopening of assessment was examined on the basis of incorrect facts, borrowed satisfaction and an uncorroborated search statement. The Tribunal noted that the recorded reasons wrongly stated that share premium had been received and even identified entities that had not been allotted shares, showing non-application of mind by the Assessing Officer. It further held that reopening could not rest only on the director's statement without supporting material, consistent with CBDT instructions discouraging additions based solely on confession. On that basis, the notice for reopening and the consequential reassessment were quashed, and the jurisdictional challenge was allowed.
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TaxTMI 
TaxTMI 
