Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Reassessment founded solely on investigation material and statements already available during prior search assessment and revision proceedings constitutes reliance on stale material and a change of opinion. Repackaging existing information does not create fresh jurisdiction to reopen assessment. Where lender-company confirmations are obtained before issuing the reassessment notice but their responses are not addressed, the reopening lacks an adequate basis. Approval based on the same pre-existing material is mechanical and does not cure the jurisdictional defect. The reassessment proceedings and consequential additions were therefore deleted.
Reassessment founded solely on investigation material and statements already available during prior search assessment and revision proceedings constitutes reliance on stale material and a change of opinion. Repackaging existing information does not create fresh jurisdiction to reopen assessment. Where lender-company confirmations are obtained before issuing the reassessment notice but their responses are not addressed, the reopening lacks an adequate basis. Approval based on the same pre-existing material is mechanical and does not cure the jurisdictional defect. The reassessment proceedings and consequential additions were therefore deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
