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...
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Section 270A penalty for under-reporting was not leviable under the provision where a health and education cess deduction claim, made in reliance on judicial decisions, was withdrawn during assessment after a retrospective amendment. Coordinate Tribunal decisions on the identical issue supported the conclusion that withdrawal of the claim did not justify penalty. The penalty was consequently deleted.
Section 270A penalty for under-reporting was not leviable under the provision where a health and education cess deduction claim, made in reliance on judicial decisions, was withdrawn during assessment after a retrospective amendment. Coordinate Tribunal decisions on the identical issue supported the conclusion that withdrawal of the claim did not justify penalty. The penalty was consequently deleted.
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