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...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
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 4884 
