Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for reopening the assessments did not meet the legal standards set forth in the Income Tax Act and relevant case law. The court found that there were only reasons to suspect, rather than reasons to believe, that income had escaped assessment. As a result, the court quashed the impugned notices and the order rejecting objections, ruling in favor of the petitioner.
Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for reopening the assessments did not meet the legal standards set forth in the Income Tax Act and relevant case law. The court found that there were only reasons to suspect, rather than reasons to believe, that income had escaped assessment. As a result, the court quashed the impugned notices and the order rejecting objections, ruling in favor of the petitioner.
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