Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Reopening of assessment u/s 147 - scope and effect of the Income Declaration Scheme (IDS) - to hold- as the High Court did, in this case, that since the assessee may have a reasonable explanation, is not a ground for quashing a notice u/s 147. As long as there is objective tangible material (in the form of documents, relevant to the issue) the sufficiency of that material cannot dictate the validity of the notice. - the High Court fell into error, in holding that the sequitur to a declaration under the IDS can lead to immunity (from taxation) in the hands of a non-declarant. - SC
Reopening of assessment u/s 147 - scope and effect of the Income Declaration Scheme (IDS) - to hold- as the High Court did, in this case, that since the assessee may have a reasonable explanation, is not a ground for quashing a notice u/s 147. As long as there is objective tangible material (in the form of documents, relevant to the issue) the sufficiency of that material cannot dictate the validity of the notice. - the High Court fell into error, in holding that the sequitur to a declaration under the IDS can lead to immunity (from taxation) in the hands of a non-declarant. - SC
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