Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
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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