External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Section 148A requires the assessee to receive information...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination before orders.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Section 148A requires the assessee to receive information suggesting income has escaped assessment, not the source of that information. Particulars in the annexure to a reassessment show-cause notice may satisfy this requirement where they identify the basis and reasons sufficiently for a response; non-disclosure of an audit objection does not invalidate the notice. However, where an assessee asserts that a taxable marked-to-market hedge-reserve amount was included in an earlier year, the assessing authority must verify that claim and its consequences. Failure to do so requires reconsideration after hearing the assessee, including additional supporting material.
Section 148A requires the assessee to receive information suggesting income has escaped assessment, not the source of that information. Particulars in the annexure to a reassessment show-cause notice may satisfy this requirement where they identify the basis and reasons sufficiently for a response; non-disclosure of an audit objection does not invalidate the notice. However, where an assessee asserts that a taxable marked-to-market hedge-reserve amount was included in an earlier year, the assessing authority must verify that claim and its consequences. Failure to do so requires reconsideration after hearing the assessee, including additional supporting material.
Note: It is a system-generated summary and is for quick reference only.