Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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