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September 26, 2026   Case Laws Income Tax
Corporate guarantees as international transactions require arm's-length pricing, while related fees cannot qualify for SEZ development deductions.
September 26, 2026   Case Laws Income Tax
Business expenditure deductions for director insurance premiums fail where policy benefits vest personally in directors, not the company.
September 26, 2026   Case Laws Income Tax
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of the adjustment.
September 26, 2026   Case Laws Income Tax
Compulsory acquisition compensation for rural agricultural land remains exempt from income tax, preventing short-term capital-gain treatment.
September 26, 2026   Case Laws Income Tax
Recorded cash sales during demonetisation cannot be taxed twice when books and stock records are accepted.
September 26, 2026   Case Laws Income Tax
Market data and secondment reimbursements: associated-enterprise recoveries were not taxable as royalty, included services, or technical services.
September 26, 2026   Case Laws Income Tax
Embedded Profit in Bogus Diamond Purchases Limits Additions Where Sales, Stock Records and Books Remain Accepted
September 26, 2026   Case Laws Income Tax
Reassessment jurisdiction requires recorded reasons to maintain a rational live nexus with the income ultimately assessed.
September 26, 2026   Case Laws Income Tax
Discounted cash flow valuation protects the taxpayer's chosen share-premium valuation method from unsupported net asset value substitution.
September 26, 2026   Case Laws Customs
Ninety-day limitation for Customs Broker licence revocation bars delayed notices and requires restoration where the deadline is missed.
September 26, 2026   Case Laws Customs
Section 50 safeguards require an independent search choice, while prolonged NDPS detention may justify bail despite prima facie evidence.
September 26, 2026   Case Laws Customs
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestablished.
September 26, 2026   Case Laws Customs
Extended customs limitation requires proof of wilful misstatement or suppression; disclosed imported rice bran claims defeat jurisdiction.
September 26, 2026   Case Laws Customs
Abetment by Customs Brokers requires evidence of knowledge, conscious involvement or collusion; document processing alone cannot justify penalty.
September 26, 2026   Case Laws Customs
Provisional bank-account attachment ends after the statutory maximum period despite pending Customs Act adjudication proceedings.
September 26, 2026   Case Laws Customs
Redemption Fine Discretion Requires Judicial Assessment Before Confiscated Prohibited Gold Jewellery Is Released on Payment
September 26, 2026   Case Laws Customs
Reasonable limitation for drawback recovery bars delayed Rule 16 action without fraud, despite an alternative statutory appeal.
September 26, 2026   Case Laws Customs
Customs classification of surgeon-used orthopaedic tools under CTH 9018 preserved spinal-instrument customs and IGST benefits.
September 26, 2026   Case Laws Customs
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than general plastics.
September 26, 2026   Case Laws Customs
Prospective customs exemption notifications bar concessional duty for earlier imports and support extended limitation for ineligible claims.

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Home › Highlights › Income Tax › 2023 › March, 2023 › This
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Income Tax

Reopening of assessment u/s 147 - Audit objection - change of...

Audit Objection on Factual Issues Can't Justify Reopening u/s 147; Change of Opinion Isn't Valid Reason.

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Income Tax March 7, 2023 Case Laws AT
Reopening of assessment u/s 147 - Audit objection - change of opinion - Reason to believe - if the audit objection on factual issue and, where, the audit party has quantified escapement, then, definitely, it does not constitute information for reopening of assessment. - AT
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