Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
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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