Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Reopening of assessment u/s 147 - Addl. CIT who has given approval for such reopening has simply mentioned that “ yes, I am satisfied that this is a fit case for issue notice of u/s 148 of I.T. Act”. A perusal of the approval given by the Addl. CIT shows that he has not applied his mind properly and has in a mechanical manner given his approval - Reassessment proceedings initiated by the AO are not as per law and has to be quashed. - AT
Reopening of assessment u/s 147 - Addl. CIT who has given approval for such reopening has simply mentioned that “ yes, I am satisfied that this is a fit case for issue notice of u/s 148 of I.T. Act”. A perusal of the approval given by the Addl. CIT shows that he has not applied his mind properly and has in a mechanical manner given his approval - Reassessment proceedings initiated by the AO are not as per law and has to be quashed. - AT
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