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...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that quashed the reassessment proceedings u/s 147 of the Income Tax Act, 1961. The court held that the reassessment proceedings were initiated based on a mere change of opinion and not on any new tangible material. The original assessment had already considered and decided on the nature of the interest paid and received, and the reassessment sought to reclassify these without any fresh evidence or rationale.
Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that quashed the reassessment proceedings u/s 147 of the Income Tax Act, 1961. The court held that the reassessment proceedings were initiated based on a mere change of opinion and not on any new tangible material. The original assessment had already considered and decided on the nature of the interest paid and received, and the reassessment sought to reclassify these without any fresh evidence or rationale.
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