Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original assessment proceedings. It observed that the impugned notice was issued based on the same issue already considered during the original assessment and lacked any fresh tangible material for reopening. The High Court held that the Assessing Officer failed to assume jurisdiction to issue the notice, especially considering that it was issued after four years from the end of the assessment year and after the framing of the original assessment.
Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original assessment proceedings. It observed that the impugned notice was issued based on the same issue already considered during the original assessment and lacked any fresh tangible material for reopening. The High Court held that the Assessing Officer failed to assume jurisdiction to issue the notice, especially considering that it was issued after four years from the end of the assessment year and after the framing of the original assessment.
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