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...
Reopening proceedings against non-existent entity/ partnership firm -The case revolves around the jurisdictional issue arising from actions taken by the assessing officer against a dissolved partnership firm. Despite the firm's amalgamation with a private limited company, the assessing officer proceeded with notices alleging non-filing of income tax returns. The petitioner challenged these actions, arguing that they were without jurisdiction since the partnership firm no longer existed. The High Court agreed with the petitioner, emphasizing that once an entity ceases to exist, no further actions can be initiated against it. It criticized the assessing officer for passing orders without proper consideration and quashed the notices issued against the petitioner.
Reopening proceedings against non-existent entity/ partnership firm -The case revolves around the jurisdictional issue arising from actions taken by the assessing officer against a dissolved partnership firm. Despite the firm's amalgamation with a private limited company, the assessing officer proceeded with notices alleging non-filing of income tax returns. The petitioner challenged these actions, arguing that they were without jurisdiction since the partnership firm no longer existed. The High Court agreed with the petitioner, emphasizing that once an entity ceases to exist, no further actions can be initiated against it. It criticized the assessing officer for passing orders without proper consideration and quashed the notices issued against the petitioner.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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