International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions the decision-making process of the Principal Commissioner of Income Tax (PCIT). Despite the petitioner's objections to the accuracy of the information, the PCIT granted approval, indicating a potential lapse in due diligence or application of mind. - The court suggests that the CIT should have either declined approval or directed the Assessing Officer to address the petitioner's concerns adequately. - The court quashes and sets aside the impugned order and notice.
Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions the decision-making process of the Principal Commissioner of Income Tax (PCIT). Despite the petitioner's objections to the accuracy of the information, the PCIT granted approval, indicating a potential lapse in due diligence or application of mind. - The court suggests that the CIT should have either declined approval or directed the Assessing Officer to address the petitioner's concerns adequately. - The court quashes and sets aside the impugned order and notice.
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