Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was held that the notice was invalid as it was issued without the required sanction from the competent authority as prescribed under section 151(1) of the Act after the expiry of four years from the end of the relevant assessment year. - The ITAT observed that the argument that the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA) extended the time limit for issuing the notice was not applicable in this case.
Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was held that the notice was invalid as it was issued without the required sanction from the competent authority as prescribed under section 151(1) of the Act after the expiry of four years from the end of the relevant assessment year. - The ITAT observed that the argument that the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA) extended the time limit for issuing the notice was not applicable in this case.
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TaxTMI 
TaxTMI 
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