Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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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