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...
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Section 148A requires the Assessing Officer to follow the prescribed sequence before issuing a reassessment notice under section 148. Where approval has been obtained to conduct an inquiry under section 148A(a), the Officer must conduct that inquiry before providing the taxpayer an opportunity to respond under section 148A(b). The text states that bypassing the approved inquiry renders the section 148A(b) notice invalid. Consequently, the subsequent order under section 148A(d) and notice under section 148 are also unsustainable. The reassessment proceedings were quashed, with the matter remitted for the required inquiry and further action in accordance with law.
Section 148A requires the Assessing Officer to follow the prescribed sequence before issuing a reassessment notice under section 148. Where approval has been obtained to conduct an inquiry under section 148A(a), the Officer must conduct that inquiry before providing the taxpayer an opportunity to respond under section 148A(b). The text states that bypassing the approved inquiry renders the section 148A(b) notice invalid. Consequently, the subsequent order under section 148A(d) and notice under section 148 are also unsustainable. The reassessment proceedings were quashed, with the matter remitted for the required inquiry and further action in accordance with law.
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