Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Delay of 1154 days in filing appeal before Commissioner of Income Tax (Appeals) was not condoned as reasons given, such as leaving income tax matters in hands of Chartered Accountant, ignorance of law, and being busy with agricultural and household activities, did not constitute "sufficient cause" u/s 249(3). Appellant remained inactive and grossly negligent after receiving assessment order, lacking due diligence. Such casual and lackadaisical approach against assessment order and consequential delay in filing appeal would not constitute "sufficient cause" u/s 249(3). Decision of Commissioner of Income Tax (Appeals) refusing to condone delay upheld.
Delay of 1154 days in filing appeal before Commissioner of Income Tax (Appeals) was not condoned as reasons given, such as leaving income tax matters in hands of Chartered Accountant, ignorance of law, and being busy with agricultural and household activities, did not constitute "sufficient cause" u/s 249(3). Appellant remained inactive and grossly negligent after receiving assessment order, lacking due diligence. Such casual and lackadaisical approach against assessment order and consequential delay in filing appeal would not constitute "sufficient cause" u/s 249(3). Decision of Commissioner of Income Tax (Appeals) refusing to condone delay upheld.
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