Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Reopening of assessment beyond the period of limitation was challenged, but the notice u/s 148 was issued within the six-year time limit on 28.03.2018 and served on 02.04.2018, complying with Section 149's requirement for issuing the notice. The legality of the assessment order was questioned due to the dismissal of the financial creditor's petition under the Insolvency & Bankruptcy Code, 2016, but the Assessing Officer had no information about the NCLT order at the time of passing the reassessment order. The addition based on audited financial statements submitted to Punjab National Bank was remitted to the Assessing Officer for de novo consideration and fresh decision, with the assessee directed to file necessary documents for proper adjudication. The appeal was partly allowed for statistical purposes.
Reopening of assessment beyond the period of limitation was challenged, but the notice u/s 148 was issued within the six-year time limit on 28.03.2018 and served on 02.04.2018, complying with Section 149's requirement for issuing the notice. The legality of the assessment order was questioned due to the dismissal of the financial creditor's petition under the Insolvency & Bankruptcy Code, 2016, but the Assessing Officer had no information about the NCLT order at the time of passing the reassessment order. The addition based on audited financial statements submitted to Punjab National Bank was remitted to the Assessing Officer for de novo consideration and fresh decision, with the assessee directed to file necessary documents for proper adjudication. The appeal was partly allowed for statistical purposes.
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