Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Reassessment u/s 147 - Cash deposition in his saving bank account - The argument that the whole of deposits cannot be regarded as income and therefore the assumption of jurisdiction is vitiated under law is not correct - so long as there is an element of income which has escaped taxation and which exceeds the maximum amount which is not chargeable to tax, the same is sufficient enough to uphold the jurisdiction u/s 147
Reassessment u/s 147 - Cash deposition in his saving bank account - The argument that the whole of deposits cannot be regarded as income and therefore the assumption of jurisdiction is vitiated under law is not correct - so long as there is an element of income which has escaped taxation and which exceeds the maximum amount which is not chargeable to tax, the same is sufficient enough to uphold the jurisdiction u/s 147
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