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...
The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being based on borrowed satisfaction without proper enquiry. The AO noted discrepancies in LTCG disclosure and re-assessed income u/s 147. However, the Tribunal found the AO's actions flawed, as the assessee had disclosed exempt income in Schedule-EI. The AO's lack of independent satisfaction led to quashing of the assessment, citing Meenakshi Overseas (P) Ltd. The appeal of the assessee was allowed.
The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being based on borrowed satisfaction without proper enquiry. The AO noted discrepancies in LTCG disclosure and re-assessed income u/s 147. However, the Tribunal found the AO's actions flawed, as the assessee had disclosed exempt income in Schedule-EI. The AO's lack of independent satisfaction led to quashing of the assessment, citing Meenakshi Overseas (P) Ltd. The appeal of the assessee was allowed.
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