Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
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 ...
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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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