Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Employee long-term reward insurance premiums do not qualify as wholly and exclusively incurred for business where policies on directors' lives are not Keyman Insurance Policies, policy proceeds vest in the directors or their nominees, and the company receives no ultimate benefit. Premium deductions were therefore denied for the relevant assessment years. Reassessment may rest on later scrutiny findings where earlier acceptance did not involve examination of policy terms; each assessment year is separate and res judicata does not strictly govern income-tax proceedings. A change-of-opinion objection fails absent prior scrutiny of the claim. A challenge alleging no statutory approval for a reassessment notice requires supporting material or evidence that approval was sought.
Employee long-term reward insurance premiums do not qualify as wholly and exclusively incurred for business where policies on directors' lives are not Keyman Insurance Policies, policy proceeds vest in the directors or their nominees, and the company receives no ultimate benefit. Premium deductions were therefore denied for the relevant assessment years. Reassessment may rest on later scrutiny findings where earlier acceptance did not involve examination of policy terms; each assessment year is separate and res judicata does not strictly govern income-tax proceedings. A change-of-opinion objection fails absent prior scrutiny of the claim. A challenge alleging no statutory approval for a reassessment notice requires supporting material or evidence that approval was sought.
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TaxTMI 
TaxTMI 
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