Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
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Reopening of assessment u/s 147 - re-assessment proceedings have been initiated beyond a period of four years - there has been full disclosure by the assessee in relation to the issues flagged in the reasons for re-assessment and the Department has not in this case discharged the statutory burden as set out in the proviso to Section 147. The impugned proceedings are held to be barred by limitation and the impugned orders are quashed. - HC
Reopening of assessment u/s 147 - re-assessment proceedings have been initiated beyond a period of four years - there has been full disclosure by the assessee in relation to the issues flagged in the reasons for re-assessment and the Department has not in this case discharged the statutory burden as set out in the proviso to Section 147. The impugned proceedings are held to be barred by limitation and the impugned orders are quashed. - HC
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