Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Reopening of assessment - reason to believe or reason to suspect - The ITAT examined the "reasons recorded" by the AO for reopening the assessment. It noted that the AO relied on the information provided by the SEBI order, which alleged manipulative trading practices by certain entities, including the director of the assessee company. However, the court observed that the name of the assessee company itself was not listed among the entities restrained by SEBI. - The Tribunal emphasized that for the reopening of an assessment, the AO must have "reasons to believe" that income has escaped assessment, not merely "reasons to suspect." It found that the information provided by the SEBI order could only trigger "reasons to suspect" and did not meet the legal requirement for reopening.
Reopening of assessment - reason to believe or reason to suspect - The ITAT examined the "reasons recorded" by the AO for reopening the assessment. It noted that the AO relied on the information provided by the SEBI order, which alleged manipulative trading practices by certain entities, including the director of the assessee company. However, the court observed that the name of the assessee company itself was not listed among the entities restrained by SEBI. - The Tribunal emphasized that for the reopening of an assessment, the AO must have "reasons to believe" that income has escaped assessment, not merely "reasons to suspect." It found that the information provided by the SEBI order could only trigger "reasons to suspect" and did not meet the legal requirement for reopening.
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