Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these transactions were found. That itself goes to prove that the ld. AO had gone into the assessment records again and had sought to entertain the change of opinion on the same set of facts available in the records.Hence, the reopening of assessment in respect of capital gain on sale of TCS Ltd. shares and re-investment in preference shares of Tata Sons Ltd., is declared as bad in law. - AT
Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these transactions were found. That itself goes to prove that the ld. AO had gone into the assessment records again and had sought to entertain the change of opinion on the same set of facts available in the records.Hence, the reopening of assessment in respect of capital gain on sale of TCS Ltd. shares and re-investment in preference shares of Tata Sons Ltd., is declared as bad in law. - AT
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