SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
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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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