Withdrawal of obsolete FEMA circulars streamlines rules on external commercial borrowings, non-resident bond investments, and money transfer sub-agent...
Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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Reassessment initiated in the name of a deceased assessee is invalid, and the resulting notice and order cannot be sustained where section 159(2)(b) applies. For extended reassessment limitation, capital gains from land may constitute income represented in the form of an asset when the sale proceeds are deposited in a bank account, because bank deposits fall within the inclusive statutory explanation. Reassessment for alleged understatement of capital gains cannot rest solely on a co-owner's valuation report. The Assessing Officer must undertake an appropriate independent valuation inquiry, examine valuation methodology, apply independent mind, and form the required belief of income escaping assessment.
Reassessment initiated in the name of a deceased assessee is invalid, and the resulting notice and order cannot be sustained where section 159(2)(b) applies. For extended reassessment limitation, capital gains from land may constitute income represented in the form of an asset when the sale proceeds are deposited in a bank account, because bank deposits fall within the inclusive statutory explanation. Reassessment for alleged understatement of capital gains cannot rest solely on a co-owner's valuation report. The Assessing Officer must undertake an appropriate independent valuation inquiry, examine valuation methodology, apply independent mind, and form the required belief of income escaping assessment.
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