Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
