Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Reopening of assessment u/s 147 - Reliance on audit objections - deemed dividend addition u/s 2(22)(e) - This Court, on an independent application of mind and on thorough consideration of material aspects and legal position, is of the considered view that there is no error or infirmity in the reasons assigned by the ITAT in dismissing the appeal filed by the Revenue
Reopening of assessment u/s 147 - Reliance on audit objections - deemed dividend addition u/s 2(22)(e) - This Court, on an independent application of mind and on thorough consideration of material aspects and legal position, is of the considered view that there is no error or infirmity in the reasons assigned by the ITAT in dismissing the appeal filed by the Revenue
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