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...
Territorial jurisdiction over an income-tax appeal and a related cross-objection is ordinarily determined by the office location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the assessment order originated from the Chennai Assessing Officer, the Mumbai Bench lacked jurisdiction over both proceedings. The appeal and cross-objection were dismissed without examination on merits, with liberty to approach the appropriate Bench. Merits remained open, and time spent before the Mumbai Bench may be considered under delay-condonation law.
Territorial jurisdiction over an income-tax appeal and a related cross-objection is ordinarily determined by the office location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the assessment order originated from the Chennai Assessing Officer, the Mumbai Bench lacked jurisdiction over both proceedings. The appeal and cross-objection were dismissed without examination on merits, with liberty to approach the appropriate Bench. Merits remained open, and time spent before the Mumbai Bench may be considered under delay-condonation law.
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