Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Reopening of assessment u/s 147 - Income from other sources or business income - The impugned reopening itself is not sustainable in the light of the alleged twin reasons recorded by the Assessing Officer which have been decided in the tribunal first round that the same did not give rise to any taxable income which could be stated to have escaped assessment in assessee's case. It is thus apparent that the impugned additions be it as income from 'other' sources or 'business', both are contrary to the tribunal's remand directions closing all options of assessing the entire credit, debit as well as estimates thereof would not help the Revenue's cause. - AT
Reopening of assessment u/s 147 - Income from other sources or business income - The impugned reopening itself is not sustainable in the light of the alleged twin reasons recorded by the Assessing Officer which have been decided in the tribunal first round that the same did not give rise to any taxable income which could be stated to have escaped assessment in assessee's case. It is thus apparent that the impugned additions be it as income from 'other' sources or 'business', both are contrary to the tribunal's remand directions closing all options of assessing the entire credit, debit as well as estimates thereof would not help the Revenue's cause. - AT
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