Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
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 
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