COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Clean-slate protection applies where a corporate debtor is sold as a going concern in liquidation: past liabilities and related investigations are extinguished, preventing an alleged past interest cessation from being imposed on the purchaser. Reassessment cannot rest on a presumption that unpaid interest was deducted when accounts and the taxpayer's reply showed otherwise. The same alleged cessation from one transaction cannot be taxed repeatedly across assessment years. Failure to address the clean-slate defence and binding precedents rendered the reassessment notice and section 148A(3) order for AY 2021-22 unsustainable and quashed.
Clean-slate protection applies where a corporate debtor is sold as a going concern in liquidation: past liabilities and related investigations are extinguished, preventing an alleged past interest cessation from being imposed on the purchaser. Reassessment cannot rest on a presumption that unpaid interest was deducted when accounts and the taxpayer's reply showed otherwise. The same alleged cessation from one transaction cannot be taxed repeatedly across assessment years. Failure to address the clean-slate defence and binding precedents rendered the reassessment notice and section 148A(3) order for AY 2021-22 unsustainable and quashed.
Note: It is a system-generated summary and is for quick reference only.
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