Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
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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