Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Reopening of assessment u/s 147 - notice under section 148 has been issued by a non jurisdictional AO - It is settled principle of law that when the notice under section 148 of the Act has been issued by a non jurisdictional AO, the ITO Bareli in this case, reassessment by the jurisdictional AO is bad in law and is liable to be quashed, more particularly when assessment of the assessee has admittedly not been transferred to Bareli under section 127 of the Act. - AT
Reopening of assessment u/s 147 - notice under section 148 has been issued by a non jurisdictional AO - It is settled principle of law that when the notice under section 148 of the Act has been issued by a non jurisdictional AO, the ITO Bareli in this case, reassessment by the jurisdictional AO is bad in law and is liable to be quashed, more particularly when assessment of the assessee has admittedly not been transferred to Bareli under section 127 of the Act. - AT
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