Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
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Post-search reassessment for assessment years preceding a search initiated after 31 March 2021 must be commenced under the reassessment framework in sections 147 and 148. Explanation 2(i) to section 148 deems such a search to be information suggesting income escapement, while exemption from the preliminary procedure under section 148A in specified search cases does not remove the mandatory section 148 notice. Compulsory scrutiny selection and a notice under section 143(2) issued under administrative guidelines cannot confer reassessment jurisdiction. Later approval or taxpayer participation cannot cure a jurisdictional defect caused by failure to issue the required notice.
Post-search reassessment for assessment years preceding a search initiated after 31 March 2021 must be commenced under the reassessment framework in sections 147 and 148. Explanation 2(i) to section 148 deems such a search to be information suggesting income escapement, while exemption from the preliminary procedure under section 148A in specified search cases does not remove the mandatory section 148 notice. Compulsory scrutiny selection and a notice under section 143(2) issued under administrative guidelines cannot confer reassessment jurisdiction. Later approval or taxpayer participation cannot cure a jurisdictional defect caused by failure to issue the required notice.
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