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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Non-conformity of a scrutiny notice under section 143(2) with the CBDT-prescribed format is treated as a procedural defect curable under section 292B, rather than one invalidating the notice or consequential assessment. In appellate proceedings, material admitted as additional evidence must be made available to the Assessing Officer for examination under Rule 46A. Deletions based on unexamined material, or made without recorded reasons, require reconsideration through a fresh, reasoned assessment after hearing the assessee. The notice challenge was rejected, while disputed additions were remitted for de novo assessment.
Non-conformity of a scrutiny notice under section 143(2) with the CBDT-prescribed format is treated as a procedural defect curable under section 292B, rather than one invalidating the notice or consequential assessment. In appellate proceedings, material admitted as additional evidence must be made available to the Assessing Officer for examination under Rule 46A. Deletions based on unexamined material, or made without recorded reasons, require reconsideration through a fresh, reasoned assessment after hearing the assessee. The notice challenge was rejected, while disputed additions were remitted for de novo assessment.
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