Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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...
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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