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Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
Assessment u/s 153C - The High court found procedural lapses in invoking Section 153C against the petitioner without concrete evidence of undisclosed transactions for the relevant assessment year. It highlighted the absence of incriminating material specific to the petitioner for the year in question, rendering the invocation of Section 153C unjustifiable. - Reassessment under Section 148: The court clarified that proceedings under Section 148, aimed at reassessing income believed to have escaped assessment, could continue provided they were based on substantive evidence and not merely on the procedural fallout of a search operation targeting a different entity.
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