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...
Transaction-specific investigation information identifying the taxpayer, supplier and disputed transaction can support reassessment under the substituted regime after pre-notice procedure; its Investigation Wing origin alone does not make it vague. A retrospective clarification permits a Jurisdictional Assessing Officer to issue the reassessment notice. Where corresponding sales, purchase records and banking evidence exist but the named supplier is untraceable and does not comply, purchases cannot be wholly disallowed; absent evidence that payments returned in cash, addition is limited to the embedded profit. The disputed-purchase addition was restricted to 6%. A monetary-limit exception for departmental appeals affects maintainability but does not itself require vacating the appellate order or remanding assessment.
Transaction-specific investigation information identifying the taxpayer, supplier and disputed transaction can support reassessment under the substituted regime after pre-notice procedure; its Investigation Wing origin alone does not make it vague. A retrospective clarification permits a Jurisdictional Assessing Officer to issue the reassessment notice. Where corresponding sales, purchase records and banking evidence exist but the named supplier is untraceable and does not comply, purchases cannot be wholly disallowed; absent evidence that payments returned in cash, addition is limited to the embedded profit. The disputed-purchase addition was restricted to 6%. A monetary-limit exception for departmental appeals affects maintainability but does not itself require vacating the appellate order or remanding assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
