Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Section 270A penalties for under-reporting or misreporting are inapplicable where an Advance Pricing Agreement governs a modified return, the royalty transaction is fully disclosed, and the revised arm's-length royalty rate is reflected in total income. A CSR expenditure deduction claim should not attract penalty where supported by binding Tribunal precedent, particularly if the underlying addition is deleted. Likewise, an education cess claim made under then-prevailing High Court precedent should not be penalised merely because a later retrospective amendment requires its withdrawal. These principles preserve the APA framework and protect bona fide, disclosed claims subsequently displaced by legal change.
Section 270A penalties for under-reporting or misreporting are inapplicable where an Advance Pricing Agreement governs a modified return, the royalty transaction is fully disclosed, and the revised arm's-length royalty rate is reflected in total income. A CSR expenditure deduction claim should not attract penalty where supported by binding Tribunal precedent, particularly if the underlying addition is deleted. Likewise, an education cess claim made under then-prevailing High Court precedent should not be penalised merely because a later retrospective amendment requires its withdrawal. These principles preserve the APA framework and protect bona fide, disclosed claims subsequently displaced by legal change.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
