Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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Validity of reopening of assessment - An order u/s 245D(4) already been passed by the Income Tax Settlement Commission (ITSC) - Scope of harmonious construction - The Delhi High Court, in this judgment, reinforced the binding and conclusive nature of orders passed by the Income Tax Settlement Commission, underscoring that once an assessment year's matters have been settled by ITSC, they cannot be reopened by the Income Tax Department under Section 147/148, except under specific circumstances of fraud or misrepresentation. This decision highlights the judiciary's commitment to uphold the finality and sanctity of ITSC's settlements, aiming to prevent administrative uncertainty and protect the interests of assessees who opt for settlement proceedings.
Validity of reopening of assessment - An order u/s 245D(4) already been passed by the Income Tax Settlement Commission (ITSC) - Scope of harmonious construction - The Delhi High Court, in this judgment, reinforced the binding and conclusive nature of orders passed by the Income Tax Settlement Commission, underscoring that once an assessment year's matters have been settled by ITSC, they cannot be reopened by the Income Tax Department under Section 147/148, except under specific circumstances of fraud or misrepresentation. This decision highlights the judiciary's commitment to uphold the finality and sanctity of ITSC's settlements, aiming to prevent administrative uncertainty and protect the interests of assessees who opt for settlement proceedings.
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