Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Validity of reopening u/s 147 r.w.s. 148 - The Tribunal found that the reasons recorded by the Assessing Officer (AO) for reopening the assessment under section 147/148 were based on incorrect assumptions and information. Specifically, the AO erroneously believed that the assessee, an individual, had entered into a transaction of sale of immovable property, whereas the transaction was actually between two partnership firms. - The Tribunal noted that the AO should have issued a notice to the partnership firm involved instead of the individual assessee. - Consequently, entire proceedings u/s. 148 is held to be invalid.
Validity of reopening u/s 147 r.w.s. 148 - The Tribunal found that the reasons recorded by the Assessing Officer (AO) for reopening the assessment under section 147/148 were based on incorrect assumptions and information. Specifically, the AO erroneously believed that the assessee, an individual, had entered into a transaction of sale of immovable property, whereas the transaction was actually between two partnership firms. - The Tribunal noted that the AO should have issued a notice to the partnership firm involved instead of the individual assessee. - Consequently, entire proceedings u/s. 148 is held to be invalid.
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