Juridical seat versus arbitral venue determines supervisory court jurisdiction, while timely award challenges remain within the prescribed limitation ...
Validity of reopening of assessment questioned due to errors in original notice. Notice alleged non-filing of return, later contradicted. AO failed to evaluate return before alleging income escape. AO's opinion on income taxation not based on due process. DTAA benefits not part of original notice. Final order relied on assessment from prior year. Allotment of shares under scheme not considered. Reassessment reasons must be consistent. Petitioner refuted remittances, claimed DTAA exemption. AO's denial of treaty benefits without original basis not valid. Court ruled in favor of assessee, criticizing AO's inconsistent approach.
Validity of reopening of assessment questioned due to errors in original notice. Notice alleged non-filing of return, later contradicted. AO failed to evaluate return before alleging income escape. AO's opinion on income taxation not based on due process. DTAA benefits not part of original notice. Final order relied on assessment from prior year. Allotment of shares under scheme not considered. Reassessment reasons must be consistent. Petitioner refuted remittances, claimed DTAA exemption. AO's denial of treaty benefits without original basis not valid. Court ruled in favor of assessee, criticizing AO's inconsistent approach.
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TaxTMI 
TaxTMI 
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