Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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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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