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...
Succession of a firm by a company satisfies section 47(xiii) where all assets and liabilities immediately before succession vest in the company and partners receive only company shares. Pre-succession capital withdrawals, asset sales and changes in partners' profit-sharing ratios do not, absent a statutory restriction, disqualify the succession or make it a taxable transfer. Search-assessment proceedings require incriminating material: routine board resolutions, no-objection certificates, legal notes, valuation reports and firm-constitution records generated in ordinary business are not incriminating. In their absence, assessment under section 153A is not maintainable, and the departmental appeal was dismissed.
Succession of a firm by a company satisfies section 47(xiii) where all assets and liabilities immediately before succession vest in the company and partners receive only company shares. Pre-succession capital withdrawals, asset sales and changes in partners' profit-sharing ratios do not, absent a statutory restriction, disqualify the succession or make it a taxable transfer. Search-assessment proceedings require incriminating material: routine board resolutions, no-objection certificates, legal notes, valuation reports and firm-constitution records generated in ordinary business are not incriminating. In their absence, assessment under section 153A is not maintainable, and the departmental appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
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