Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Reopening of assessment u/s 147 - Whether AO has assumed the jurisdiction on wrong facts? - The date of filing of the return is much before than the date of recording of reasons which is 27.03.2019. AO has noted that PAN was searched in the system and DCR of respective year has also been consulted and he had not found the copy of return filed by assessee. In view of the fact of having filed the return of income by the assessee the finding of the Assessing Officer that no return has been furnished by the assessee is wrong and therefore AO has reopened the case by recording a wrong fact. - AT
Reopening of assessment u/s 147 - Whether AO has assumed the jurisdiction on wrong facts? - The date of filing of the return is much before than the date of recording of reasons which is 27.03.2019. AO has noted that PAN was searched in the system and DCR of respective year has also been consulted and he had not found the copy of return filed by assessee. In view of the fact of having filed the return of income by the assessee the finding of the Assessing Officer that no return has been furnished by the assessee is wrong and therefore AO has reopened the case by recording a wrong fact. - AT
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TaxTMI 
TaxTMI 
of 4888 
