Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Revision u/s 264 - Exclusion of income declared under Income Declaration Scheme, 2016 ("IDS") - Petitioner having paid the tax and surcharge and the penalty with interest, amount of undisclosed income cannot be included in the income of the declarant/petitioner. Therefore, in our view, Commissioner should have exercised his power u/s 264 of the Act and decide the matter on merits. - HC
Revision u/s 264 - Exclusion of income declared under Income Declaration Scheme, 2016 ("IDS") - Petitioner having paid the tax and surcharge and the penalty with interest, amount of undisclosed income cannot be included in the income of the declarant/petitioner. Therefore, in our view, Commissioner should have exercised his power u/s 264 of the Act and decide the matter on merits. - HC
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