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 under section 148A requires information that rationally and directly suggests income escapement; mere suspicion, a need for further scrutiny, or a verification objective is insufficient. The material and the taxpayer's response must be considered in a speaking order before a case is treated as fit for reassessment. Treating an entire trust's expenditure over several years as unexplained, despite accounts, bank records and vouchers, without identifying a false explanation or unaccounted amount, constitutes an impermissible roving or fishing inquiry. The reassessment order and consequential notice for the relevant assessment year were set aside.
Reassessment under section 148A requires information that rationally and directly suggests income escapement; mere suspicion, a need for further scrutiny, or a verification objective is insufficient. The material and the taxpayer's response must be considered in a speaking order before a case is treated as fit for reassessment. Treating an entire trust's expenditure over several years as unexplained, despite accounts, bank records and vouchers, without identifying a false explanation or unaccounted amount, constitutes an impermissible roving or fishing inquiry. The reassessment order and consequential notice for the relevant assessment year were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
