Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
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Once the original reassessment orders u/s 148 were quashed, they ceased to exist legally. The rectification order u/s 154 was premised on the quashed orders, which could not be revived or corrected. Section 154 could only be invoked if a valid order capable of rectification existed. Since the original orders were non-existent after being quashed, invoking Section 154 was impermissible. Additionally, the condition u/s 149(1)(b) requiring income escaping assessment to be Rs. 50 lakhs or more was not fulfilled. Consequently, the rectification order was unsustainable and quashed by the High Court.
Once the original reassessment orders u/s 148 were quashed, they ceased to exist legally. The rectification order u/s 154 was premised on the quashed orders, which could not be revived or corrected. Section 154 could only be invoked if a valid order capable of rectification existed. Since the original orders were non-existent after being quashed, invoking Section 154 was impermissible. Additionally, the condition u/s 149(1)(b) requiring income escaping assessment to be Rs. 50 lakhs or more was not fulfilled. Consequently, the rectification order was unsustainable and quashed by the High Court.
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