Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
The High Court addressed the validity of a certification issued u/s 197 for FY 2023-24, where a "Nil" withholding tax certificate was sought but a 15% withholding tax rate was prescribed. Since FY 2023-24 has ended, the petition was disposed with liberty to apply u/s 197 for FY 2024-25. Any new application will be reviewed independently. The petitioner may claim benefits as per CBDT Circular if successful. The petitioner retains the right to challenge the impugned order to safeguard its interests. All rights and contentions of parties are preserved.
The High Court addressed the validity of a certification issued u/s 197 for FY 2023-24, where a "Nil" withholding tax certificate was sought but a 15% withholding tax rate was prescribed. Since FY 2023-24 has ended, the petition was disposed with liberty to apply u/s 197 for FY 2024-25. Any new application will be reviewed independently. The petitioner may claim benefits as per CBDT Circular if successful. The petitioner retains the right to challenge the impugned order to safeguard its interests. All rights and contentions of parties are preserved.
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