Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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Section 153D approval of draft search-assessment orders operates as a safeguard against arbitrary assessment and requires independent application of mind to the material and reasoning for each assessment year. A consolidated approval that does not record examination or movement of files, provide separate year-wise approvals, or state reasons is mechanical and fails the prior-approval requirement. Such defective approval invalidates the consequential assessment order; the assessment was therefore treated as void and quashed, while the remaining grounds were left open.
Section 153D approval of draft search-assessment orders operates as a safeguard against arbitrary assessment and requires independent application of mind to the material and reasoning for each assessment year. A consolidated approval that does not record examination or movement of files, provide separate year-wise approvals, or state reasons is mechanical and fails the prior-approval requirement. Such defective approval invalidates the consequential assessment order; the assessment was therefore treated as void and quashed, while the remaining grounds were left open.
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