Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Clause 2(c) of the 2006 interest waiver/reduction scheme requires non-payment of tax to result from a jurisdictional High Court ruling that governed the taxpayer when advance tax was paid or the return was filed. A later ruling does not satisfy that condition, and waiver also requires prior payment of the principal income-tax demand. Challenges to the underlying interest liability cannot be pursued in proceedings confined to a waiver application. Interest under section 220(2) arises only after default in paying a demand served under section 156 within the prescribed period. Waiver rejection was sustained, while taxpayers may seek refund of excess section 220(2) interest if charged from the return-filing date.
Clause 2(c) of the 2006 interest waiver/reduction scheme requires non-payment of tax to result from a jurisdictional High Court ruling that governed the taxpayer when advance tax was paid or the return was filed. A later ruling does not satisfy that condition, and waiver also requires prior payment of the principal income-tax demand. Challenges to the underlying interest liability cannot be pursued in proceedings confined to a waiver application. Interest under section 220(2) arises only after default in paying a demand served under section 156 within the prescribed period. Waiver rejection was sustained, while taxpayers may seek refund of excess section 220(2) interest if charged from the return-filing date.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
