Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Reopening of assessment u/s 147 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant provisions of the Income Tax Act. It suggested a thorough examination of whether Section 153(C) should have been invoked instead of Sections 147 and 148, especially considering the circumstances of the case. The Court highlighted the importance of procedural fairness and the duty of the Assessing Officer to provide all necessary documents and material to the Assessee. It emphasized the need for compliance with procedural safeguards to ensure a fair assessment process.
Reopening of assessment u/s 147 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant provisions of the Income Tax Act. It suggested a thorough examination of whether Section 153(C) should have been invoked instead of Sections 147 and 148, especially considering the circumstances of the case. The Court highlighted the importance of procedural fairness and the duty of the Assessing Officer to provide all necessary documents and material to the Assessee. It emphasized the need for compliance with procedural safeguards to ensure a fair assessment process.
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