Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
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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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