SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
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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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