Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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