Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening of concluded assessments. The procedure outlined in Ashish Agarwal primarily concerned notices that were challenged before various High Courts but had not yet attained finality. The High Court clarified that Ashish Agarwal did not authorize completed assessments to be reopened, especially in cases where no objection had been raised to the initiation of proceedings.
Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening of concluded assessments. The procedure outlined in Ashish Agarwal primarily concerned notices that were challenged before various High Courts but had not yet attained finality. The High Court clarified that Ashish Agarwal did not authorize completed assessments to be reopened, especially in cases where no objection had been raised to the initiation of proceedings.
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