Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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Reopening of assessment u/s 147 - When the A.O. admits in the notice under section 142(1) Dated 20.10.2014 that assessee filed return of income under section 148 of the I.T. Act, it would strengthen the findings of the Ld. CIT(A) that assessee made a request before A.O. that original return filed may be treated as return filed in response to notice under section 148 of the I.T. Act, 1961. Since no notice under section 143(2) have been issued by the A.O. before completion of the assessment within the period of limitation, therefore, the Ld. CIT(A) was justified in quashing the re-assessment proceedings. - AT
Reopening of assessment u/s 147 - When the A.O. admits in the notice under section 142(1) Dated 20.10.2014 that assessee filed return of income under section 148 of the I.T. Act, it would strengthen the findings of the Ld. CIT(A) that assessee made a request before A.O. that original return filed may be treated as return filed in response to notice under section 148 of the I.T. Act, 1961. Since no notice under section 143(2) have been issued by the A.O. before completion of the assessment within the period of limitation, therefore, the Ld. CIT(A) was justified in quashing the re-assessment proceedings. - AT
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