Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Section 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.
Section 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.
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TaxTMI 
TaxTMI 
of 4888 
