Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Recording reasons before issuing a reassessment notice and obtaining sanction based on independent application of mind are jurisdictional requirements. The note explains that undated recorded reasons and an undated sanction are invalid where the sanctioning authority merely writes "yes" or "approved" on a prescribed proforma without demonstrating consideration of the material. Such mechanical approval vitiates the reassessment proceedings. On these facts, the reassessment and consequential assessment order were quashed as bad in law, while other grounds became academic.
Recording reasons before issuing a reassessment notice and obtaining sanction based on independent application of mind are jurisdictional requirements. The note explains that undated recorded reasons and an undated sanction are invalid where the sanctioning authority merely writes "yes" or "approved" on a prescribed proforma without demonstrating consideration of the material. Such mechanical approval vitiates the reassessment proceedings. On these facts, the reassessment and consequential assessment order were quashed as bad in law, while other grounds became academic.
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