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 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.
Section 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.
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