Urgent interim relief exception permits commercial suit without pre-institution mediation where immediate disclosure and asset protection are genuinel...
Portal order discrepancies invalidated rectification rejection, requiring fresh reasoned consideration after hearing and prompt communication of the o...
Reassessment requires recorded material to have a rational connection and live nexus with the belief that income escaped assessment; suspicion based on statements or survey material unrelated to the taxpayer or investment transaction is insufficient. Allegations concerning an investor's representative, without transaction-specific material, could not support reopening for purportedly non-genuine share capital and share premium. For employees' provident fund and insurance contributions, the law prevailing when notice was issued allowed deduction where payment was made by the return-filing due date. A later contrary Supreme Court ruling could not retrospectively validate the recorded reason. The reassessment notice was quashed because neither ground established a sustainable reason to believe.
Reassessment requires recorded material to have a rational connection and live nexus with the belief that income escaped assessment; suspicion based on statements or survey material unrelated to the taxpayer or investment transaction is insufficient. Allegations concerning an investor's representative, without transaction-specific material, could not support reopening for purportedly non-genuine share capital and share premium. For employees' provident fund and insurance contributions, the law prevailing when notice was issued allowed deduction where payment was made by the return-filing due date. A later contrary Supreme Court ruling could not retrospectively validate the recorded reason. The reassessment notice was quashed because neither ground established a sustainable reason to believe.
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