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...
Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.
Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
