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...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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The search-penalty framework under section 271AAB(1) requires a finding that surrendered income meets the statutory definition of undisclosed income; surrender during search alone is insufficient. The notice and penalty order must specify the applicable statutory default or clause, because an admission in a search statement does not automatically attract the provision. Where the assessment order is appealed, search-penalty proceedings must be completed within six months of receipt of the appellate order; an order issued after that period is barred by limitation.
The search-penalty framework under section 271AAB(1) requires a finding that surrendered income meets the statutory definition of undisclosed income; surrender during search alone is insufficient. The notice and penalty order must specify the applicable statutory default or clause, because an admission in a search statement does not automatically attract the provision. Where the assessment order is appealed, search-penalty proceedings must be completed within six months of receipt of the appellate order; an order issued after that period is barred by limitation.
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