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...
Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.
Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
