Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Page of 4891
Press 'Enter' after typing page number.
21 to 40 of 97811 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Section 170A(2)(a) limits a modified return filed after business...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer-pricing proceedings.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Section 170A(2)(a) limits a modified return filed after business reorganisation, where assessment or reassessment had already concluded, to adjusting total income to implement the reorganisation. It does not permit the modified return to be treated as a return under section 139 or to initiate fresh scrutiny under section 143(2); information may be sought only to verify implementation. Transfer-pricing jurisdiction initiated on the premise of valid pending scrutiny does not survive if that scrutiny notice lacks authority. A writ challenging the assumption of statutory jurisdiction remains maintainable despite assessment participation or an appellate remedy. The scrutiny and consequential transfer-pricing proceedings were quashed.
Section 170A(2)(a) limits a modified return filed after business reorganisation, where assessment or reassessment had already concluded, to adjusting total income to implement the reorganisation. It does not permit the modified return to be treated as a return under section 139 or to initiate fresh scrutiny under section 143(2); information may be sought only to verify implementation. Transfer-pricing jurisdiction initiated on the premise of valid pending scrutiny does not survive if that scrutiny notice lacks authority. A writ challenging the assumption of statutory jurisdiction remains maintainable despite assessment participation or an appellate remedy. The scrutiny and consequential transfer-pricing proceedings were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
