Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reassessment after four years may proceed where a taxpayer credits a waived retired partner's capital balance but claims its exclusion from taxable income without disclosing supporting facts or the basis of non-taxability. The material states that such omission can amount to failure of full and true disclosure, and recorded reasons need only show a live link to a prima facie belief of escaped income; reassessment was sustained. On taxability, the taxpayer must substantiate the account composition, conversion to unsecured loan, retirement arrangement and waiver, while the assessing authority must identify the charging provision and give reasons. The addition was remanded for de novo, reasoned determination.
Reassessment after four years may proceed where a taxpayer credits a waived retired partner's capital balance but claims its exclusion from taxable income without disclosing supporting facts or the basis of non-taxability. The material states that such omission can amount to failure of full and true disclosure, and recorded reasons need only show a live link to a prima facie belief of escaped income; reassessment was sustained. On taxability, the taxpayer must substantiate the account composition, conversion to unsecured loan, retirement arrangement and waiver, while the assessing authority must identify the charging provision and give reasons. The addition was remanded for de novo, reasoned determination.
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