Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Modified returns of income filed following business...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer pricing action.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Modified returns of income filed following business reorganisation must be considered within the assessment proceedings already pending for the relevant assessment year. A draft assessment order does not conclude those proceedings, as the Dispute Resolution Panel process remains part of the assessment machinery until a final appealable order is issued. Section 170A does not extinguish the existing assessment or permit a separate, parallel scrutiny process for the modified return. A scrutiny notice issued without jurisdiction cannot support a transfer pricing reference; consequential Transfer Pricing Officer proceedings and notices founded on that scrutiny are unsustainable and liable to be quashed.
Modified returns of income filed following business reorganisation must be considered within the assessment proceedings already pending for the relevant assessment year. A draft assessment order does not conclude those proceedings, as the Dispute Resolution Panel process remains part of the assessment machinery until a final appealable order is issued. Section 170A does not extinguish the existing assessment or permit a separate, parallel scrutiny process for the modified return. A scrutiny notice issued without jurisdiction cannot support a transfer pricing reference; consequential Transfer Pricing Officer proceedings and notices founded on that scrutiny are unsustainable and liable to be quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
