Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following the directions given by the PCIT - The High Court held that such a notice could not be issued as long as assessment proceedings were ongoing, as income cannot be considered to have escaped assessment until these proceedings are completed. Additionally, the court found the sanction granted under Section 151 of the Act to be invalid based on a previous ruling. Consequently, the petition was disposed of in favor of the petitioner.
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