Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Return filed in response to a reassessment notice may be treated as a regular return where delayed filing was bona fide because an advance-ruling application on the taxability of the sole transaction remained pending. Credit of tax deducted at source and other prepaid taxes must be allowed against the assessed demand; once such adjustment is permissible, excess prepaid tax cannot be denied as a refund without statutory basis. Fresh assessment must verify the prepaid-tax credits, grant any resulting refund with applicable interest, and may entail fresh penalty proceedings where warranted.
Return filed in response to a reassessment notice may be treated as a regular return where delayed filing was bona fide because an advance-ruling application on the taxability of the sole transaction remained pending. Credit of tax deducted at source and other prepaid taxes must be allowed against the assessed demand; once such adjustment is permissible, excess prepaid tax cannot be denied as a refund without statutory basis. Fresh assessment must verify the prepaid-tax credits, grant any resulting refund with applicable interest, and may entail fresh penalty proceedings where warranted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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