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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Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
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