Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Demand and penalty-initiation notices cannot rest on an order expressly issued as a draft assessment order. Where proposed disallowances remain proposals, no demand or penalty notice is issued, and the taxpayer retains the right to accept variations or object before final assessment, the payable sum has not been finally determined. Such a defect is not a mere uploading error curable through Section 292B, especially without a subsequent corrective or clarificatory order. Draft assessment procedure is also unavailable where the Transfer Pricing Officer makes no variation to returned income from international transactions; the taxpayer is then not an eligible assessee under Section 144C. The draft order and consequential notices were set aside.
Demand and penalty-initiation notices cannot rest on an order expressly issued as a draft assessment order. Where proposed disallowances remain proposals, no demand or penalty notice is issued, and the taxpayer retains the right to accept variations or object before final assessment, the payable sum has not been finally determined. Such a defect is not a mere uploading error curable through Section 292B, especially without a subsequent corrective or clarificatory order. Draft assessment procedure is also unavailable where the Transfer Pricing Officer makes no variation to returned income from international transactions; the taxpayer is then not an eligible assessee under Section 144C. The draft order and consequential notices were set aside.
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