Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Rejection of refund claim - finalization of provisional assessment or not - A provisional assessment will always remain as a provisional one. There is no shortcut as a deemed finalization since the authorities can only collect the tax/duty as permissible under law. Hence, the non-finalization of the provisional assessment has lead to a situation where the duty paid by the unsuspecting assessee has been retained in full without following the process of law since it is observed that a provisional assessment will not automatically become final but the same has to be taken to its logical conclusion by passing a final order. - AT
Rejection of refund claim - finalization of provisional assessment or not - A provisional assessment will always remain as a provisional one. There is no shortcut as a deemed finalization since the authorities can only collect the tax/duty as permissible under law. Hence, the non-finalization of the provisional assessment has lead to a situation where the duty paid by the unsuspecting assessee has been retained in full without following the process of law since it is observed that a provisional assessment will not automatically become final but the same has to be taken to its logical conclusion by passing a final order. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
