Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Reopening of assessment u/s 147 - excessive share premium - The High Court observed that, the reopening of an assessment requires a valid "reason to believe" based on new tangible material, not merely a change of opinion or directives from higher authorities. Additionally, share premium received on issuance of fresh shares is considered a capital receipt, not income, and thus not taxable under the Act for the assessment year in question.
Reopening of assessment u/s 147 - excessive share premium - The High Court observed that, the reopening of an assessment requires a valid "reason to believe" based on new tangible material, not merely a change of opinion or directives from higher authorities. Additionally, share premium received on issuance of fresh shares is considered a capital receipt, not income, and thus not taxable under the Act for the assessment year in question.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
