Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Reopening of assessment - Reasons to believe - ACIT jurisdiction to issue the notice u/s 148 - The Tribunal concluded that the reasons for reopening were based on credible information from the Investigation Wing, providing sufficient grounds for prima facie belief of income escapement. The approval from the PCIT, although brief, was considered valid as there was no evidence indicating lack of proper application of mind. - The Tribunal rejected the appellant's argument about the notice being issued after the prescribed time limit, noting that the acknowledgment from the postal authorities confirmed receipt within the deadline. Objections regarding reasons for issuing notices under section 143(2) and inadequate time for compliance were deemed meritless.
Reopening of assessment - Reasons to believe - ACIT jurisdiction to issue the notice u/s 148 - The Tribunal concluded that the reasons for reopening were based on credible information from the Investigation Wing, providing sufficient grounds for prima facie belief of income escapement. The approval from the PCIT, although brief, was considered valid as there was no evidence indicating lack of proper application of mind. - The Tribunal rejected the appellant's argument about the notice being issued after the prescribed time limit, noting that the acknowledgment from the postal authorities confirmed receipt within the deadline. Objections regarding reasons for issuing notices under section 143(2) and inadequate time for compliance were deemed meritless.
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