Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of which is the failure to disclose all material facts. - The Court observed that while the Assessing Officer had invoked the extended period of limitation for reassessment, there was no finding in the reasons furnished for reassessment that the petitioner had failed to disclose fully and truly all material facts necessary for assessment. Without such a finding, the Court held that the entire proceeding would be void and a nullity.
Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of which is the failure to disclose all material facts. - The Court observed that while the Assessing Officer had invoked the extended period of limitation for reassessment, there was no finding in the reasons furnished for reassessment that the petitioner had failed to disclose fully and truly all material facts necessary for assessment. Without such a finding, the Court held that the entire proceeding would be void and a nullity.
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