Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Determination of tax liability and treatment as Association of Persons (AOP) for assessee trusts. Examination required on whether income taxable at slab rates u/s 164(1) or as AOP u/s 167B at Maximum Marginal Rate. Rectification application pending u/s 154. Issue restored to Assessing Officer for fresh consideration after examining all relevant details and documents. Appeals allowed for statistical purposes. Jurisdictional Assessing Officer to examine and verify necessary details for determining appropriate tax treatment.
Determination of tax liability and treatment as Association of Persons (AOP) for assessee trusts. Examination required on whether income taxable at slab rates u/s 164(1) or as AOP u/s 167B at Maximum Marginal Rate. Rectification application pending u/s 154. Issue restored to Assessing Officer for fresh consideration after examining all relevant details and documents. Appeals allowed for statistical purposes. Jurisdictional Assessing Officer to examine and verify necessary details for determining appropriate tax treatment.
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