Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.
Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
