Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.
Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
