Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Reassessment proceedings under section 147 are confined to bringing escaped or under-assessed income to tax and cannot be used by an assessee to reopen a concluded matter or withdraw income voluntarily offered in the original return. Where the income had been disclosed under section 139(1), a return filed in response to section 148 could not be used to reduce assessed house property income or obtain review of the original position. The addition was sustained, the merits of the ownership-based explanation were left open as academic, and the appellate order was upheld.
Reassessment proceedings under section 147 are confined to bringing escaped or under-assessed income to tax and cannot be used by an assessee to reopen a concluded matter or withdraw income voluntarily offered in the original return. Where the income had been disclosed under section 139(1), a return filed in response to section 148 could not be used to reduce assessed house property income or obtain review of the original position. The addition was sustained, the merits of the ownership-based explanation were left open as academic, and the appellate order was upheld.
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