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...
Reassessment based on additions identical to those made in an original search assessment cannot proceed while tax appeals challenging that assessment remain pending, where the original appellate authority considered the additions on merits as well as technical grounds. The High Court found that parallel reassessment would directly affect the pending appeals. Precedent permitting reassessment after an assessment was annulled solely on a technical ground did not apply. The reopening notice and consequential reassessment orders were quashed; the merits of the additions remain to be decided in the pending tax appeals.
Reassessment based on additions identical to those made in an original search assessment cannot proceed while tax appeals challenging that assessment remain pending, where the original appellate authority considered the additions on merits as well as technical grounds. The High Court found that parallel reassessment would directly affect the pending appeals. Precedent permitting reassessment after an assessment was annulled solely on a technical ground did not apply. The reopening notice and consequential reassessment orders were quashed; the merits of the additions remain to be decided in the pending tax appeals.
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