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...
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The ITAT Indore ruled on the validity of reopening assessment u/s 147 based on information from DDIT (Inv.)-Unit 2(2), Kolkata alleging sham transactions with a shell company. Assessee consistently denied such transactions. Tribunal found no evidence of transactions with the alleged shell company, rendering the reassessment invalid. The AO cannot make new additions unrelated to original reasons u/s 147. The 3rd Proviso restricts AO to reassess only matters not subject to appeal, reference, or revision. Relying on Jet Airways case, the reassessment order was quashed, and the assessee succeeded in the appeal.
The ITAT Indore ruled on the validity of reopening assessment u/s 147 based on information from DDIT (Inv.)-Unit 2(2), Kolkata alleging sham transactions with a shell company. Assessee consistently denied such transactions. Tribunal found no evidence of transactions with the alleged shell company, rendering the reassessment invalid. The AO cannot make new additions unrelated to original reasons u/s 147. The 3rd Proviso restricts AO to reassess only matters not subject to appeal, reference, or revision. Relying on Jet Airways case, the reassessment order was quashed, and the assessee succeeded in the appeal.
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