Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Partial appellate remand of transfer-pricing comparability issues, without setting aside or cancelling the assessment, requires effect to be given otherwise than through a fresh assessment. Where the remand requires fresh examination and hearing, the limitation period applicable to consequential action applies. A Tribunal remand to the Transfer Pricing Officer does not constitute an Assessing Officer's reference to that officer and therefore does not trigger the additional limitation extension available for such a reference. The consequential assessment, completed after the prescribed deadline, was quashed as time-barred; the remaining transfer-pricing challenges became infructuous.
Partial appellate remand of transfer-pricing comparability issues, without setting aside or cancelling the assessment, requires effect to be given otherwise than through a fresh assessment. Where the remand requires fresh examination and hearing, the limitation period applicable to consequential action applies. A Tribunal remand to the Transfer Pricing Officer does not constitute an Assessing Officer's reference to that officer and therefore does not trigger the additional limitation extension available for such a reference. The consequential assessment, completed after the prescribed deadline, was quashed as time-barred; the remaining transfer-pricing challenges became infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
