Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Explanation to amended section 147 permits an ongoing reassessment to be enlarged for any escaped-income issue subsequently noticed, without separate compliance with the section 148A procedure. Removal of "and also" from the substantive provision distinguishes prior interpretations of the unamended law. Its wording and context show legislative intent to expand rather than merely clarify reassessment scope. "Any issue" covers material obtained after commencement from sources outside the original proceedings, including search material. Authorities may use such material to enlarge a pending reassessment for the same assessment year, despite a separate search-assessment mechanism.
Explanation to amended section 147 permits an ongoing reassessment to be enlarged for any escaped-income issue subsequently noticed, without separate compliance with the section 148A procedure. Removal of "and also" from the substantive provision distinguishes prior interpretations of the unamended law. Its wording and context show legislative intent to expand rather than merely clarify reassessment scope. "Any issue" covers material obtained after commencement from sources outside the original proceedings, including search material. Authorities may use such material to enlarge a pending reassessment for the same assessment year, despite a separate search-assessment mechanism.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
