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...
Valid information for reassessment must point to income that escaped tax, not receipts disclosed, accounted for and taxed by the resulting company following a corporate demerger. Transactions appearing under the demerged entity's PAN because tax was deducted in its name before demerger sanction do not, without more, establish escapement. The extended reassessment period applies only where books, documents or evidence reveal previously undisclosed income meeting the prescribed threshold; material requiring only correlation of already disclosed transactions is insufficient. On these grounds, reassessment for the relevant assessment year was set aside as unsupported by valid information and time-barred.
Valid information for reassessment must point to income that escaped tax, not receipts disclosed, accounted for and taxed by the resulting company following a corporate demerger. Transactions appearing under the demerged entity's PAN because tax was deducted in its name before demerger sanction do not, without more, establish escapement. The extended reassessment period applies only where books, documents or evidence reveal previously undisclosed income meeting the prescribed threshold; material requiring only correlation of already disclosed transactions is insufficient. On these grounds, reassessment for the relevant assessment year was set aside as unsupported by valid information and time-barred.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
