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...
Validity of re-opening of assessment u/s 147 - Procedure of recording satisfaction for reopening assessment - notice beyond period of four years - The ITAT observed that, in the income tax return assessee has disclosed long term capital gain, but AO in the reasons recorded has mentioned short term capital gain/loss which means that he was not sure of the transactions for which the reopening is carried out. Further, AO has mentioned the figure as long term capital gain/short term capital loss. This observation is also factually incorrect. - The ITAT held that the re-opening of assessment u/s 147 was invalid due to non-compliance with procedural requirements and lack of independent application of mind by the AO.
Validity of re-opening of assessment u/s 147 - Procedure of recording satisfaction for reopening assessment - notice beyond period of four years - The ITAT observed that, in the income tax return assessee has disclosed long term capital gain, but AO in the reasons recorded has mentioned short term capital gain/loss which means that he was not sure of the transactions for which the reopening is carried out. Further, AO has mentioned the figure as long term capital gain/short term capital loss. This observation is also factually incorrect. - The ITAT held that the re-opening of assessment u/s 147 was invalid due to non-compliance with procedural requirements and lack of independent application of mind by the AO.
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