Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Reopening of assessment u/s 147 - eligibility of reasons to believe - the foundation on which the AO based his belief that income chargeable to tax had escaped assessment was absent at the material time when he issued notice u/s. 148, and therefore, the basic legal requirement of reopening u/s. 148 of the Act i.e. AO’s formation of reasons to believe escapement of income prior to reopening of assessment was absent in the given facts of the present case. - AT
Reopening of assessment u/s 147 - eligibility of reasons to believe - the foundation on which the AO based his belief that income chargeable to tax had escaped assessment was absent at the material time when he issued notice u/s. 148, and therefore, the basic legal requirement of reopening u/s. 148 of the Act i.e. AO’s formation of reasons to believe escapement of income prior to reopening of assessment was absent in the given facts of the present case. - AT
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