Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Penalty proceedings under section 271D that are not initiated during an assessment or other proceeding fall outside the first alternative limitation period in section 275(1)(c). In that situation, the show-cause notice constitutes the latest point at which action to impose the penalty is regarded as initiated. The penalty order must therefore be made within six months from the end of the month in which that notice is issued. An order made after that deadline is time-barred and cannot sustain the penalty.
Penalty proceedings under section 271D that are not initiated during an assessment or other proceeding fall outside the first alternative limitation period in section 275(1)(c). In that situation, the show-cause notice constitutes the latest point at which action to impose the penalty is regarded as initiated. The penalty order must therefore be made within six months from the end of the month in which that notice is issued. An order made after that deadline is time-barred and cannot sustain the penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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