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...
Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.
Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
