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...
The proviso to Section 270AA(4) bars rejection of a penalty-immunity application without a meaningful opportunity of hearing. Notice requiring appearance on the following day, followed by immediate rejection, was insufficient to allow applicants to present and substantiate their claims. The rejection orders were set aside, and the applications were remitted for fresh consideration after hearing the applicants and considering their material. Assessing Authorities were entitled to await expiry of the prescribed appeal period before deciding the applications; that delay did not invalidate the process.
The proviso to Section 270AA(4) bars rejection of a penalty-immunity application without a meaningful opportunity of hearing. Notice requiring appearance on the following day, followed by immediate rejection, was insufficient to allow applicants to present and substantiate their claims. The rejection orders were set aside, and the applications were remitted for fresh consideration after hearing the applicants and considering their material. Assessing Authorities were entitled to await expiry of the prescribed appeal period before deciding the applications; that delay did not invalidate the process.
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TaxTMI 
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