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...
Reassessment requires the prescribed preliminary inquiry and independent application of mind; reliance solely on external reports fails the statutory preconditions and renders initiation without jurisdiction. An approved corporate insolvency resolution plan precludes reassessment or revision of pre-effective-date claims that were not included in the plan, as such claims are frozen or extinguished under the overriding insolvency framework. Complete disclosure of relied-upon third-party statements and materials is necessary to afford a fair rebuttal opportunity; non-disclosure breaches natural justice. Reassessment must also commence within the Income-tax Act's prescribed limitation period; proceedings initiated after that period are invalid.
Reassessment requires the prescribed preliminary inquiry and independent application of mind; reliance solely on external reports fails the statutory preconditions and renders initiation without jurisdiction. An approved corporate insolvency resolution plan precludes reassessment or revision of pre-effective-date claims that were not included in the plan, as such claims are frozen or extinguished under the overriding insolvency framework. Complete disclosure of relied-upon third-party statements and materials is necessary to afford a fair rebuttal opportunity; non-disclosure breaches natural justice. Reassessment must also commence within the Income-tax Act's prescribed limitation period; proceedings initiated after that period are invalid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
