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...
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Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.
Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.
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