Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Final settlement orders under section 245D(4) cover statutory deductions disclosed in the settlement application, including a section 80IB(10) housing-project deduction. Chapter XIX-A permits departure from that finality only when the Settlement Commission declares its order void for fraud or misrepresentation. It does not preserve a parallel power for the Assessing Officer to reopen, under sections 147 and 148, deduction issues already covered by the final settlement. Where the prescribed recourse to challenge the settlement order has been rejected and attained finality, reassessment of that deduction is unsustainable.
Final settlement orders under section 245D(4) cover statutory deductions disclosed in the settlement application, including a section 80IB(10) housing-project deduction. Chapter XIX-A permits departure from that finality only when the Settlement Commission declares its order void for fraud or misrepresentation. It does not preserve a parallel power for the Assessing Officer to reopen, under sections 147 and 148, deduction issues already covered by the final settlement. Where the prescribed recourse to challenge the settlement order has been rejected and attained finality, reassessment of that deduction is unsustainable.
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