Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Exemption u/s 10(26) - Exemption to individual members of Scheduled Tribes - Whether a partnership firm, formed by individual partners who are entitled to an exemption u/s 10(26), can claim the same exemption. - The tribunal observed that under the Income Tax Act, a partnership firm is treated as a separate and distinct entity from its partners. The Act expressly includes firms in the definition of "person" for the purpose of tax assessment, making them separately assessable entities. - The exemption u/s 10(26) of the Income Tax Act, specifically granted to individual members of Scheduled Tribes, cannot be extended to partnership firms, even if they are solely constituted of such individuals.
Exemption u/s 10(26) - Exemption to individual members of Scheduled Tribes - Whether a partnership firm, formed by individual partners who are entitled to an exemption u/s 10(26), can claim the same exemption. - The tribunal observed that under the Income Tax Act, a partnership firm is treated as a separate and distinct entity from its partners. The Act expressly includes firms in the definition of "person" for the purpose of tax assessment, making them separately assessable entities. - The exemption u/s 10(26) of the Income Tax Act, specifically granted to individual members of Scheduled Tribes, cannot be extended to partnership firms, even if they are solely constituted of such individuals.
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