Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The Income Tax Appellate Tribunal held that the Assessing Officer had rightly formed a 'reason to believe' and not merely a 'reason to suspect' regarding escapement of income based on the assessee's investment in property being disproportionate to their disclosed income. The approval u/s 151(2) for reopening assessment was properly granted after due application of mind by the Principal Commissioner. However, the Tribunal directed deletion of the addition made u/s 69 regarding unexplained investment, as the assessee had duly explained their share of the investment, while leaving the issue of unsecured loan and jewellery amount received by the assessee's wife to be examined separately.
The Income Tax Appellate Tribunal held that the Assessing Officer had rightly formed a 'reason to believe' and not merely a 'reason to suspect' regarding escapement of income based on the assessee's investment in property being disproportionate to their disclosed income. The approval u/s 151(2) for reopening assessment was properly granted after due application of mind by the Principal Commissioner. However, the Tribunal directed deletion of the addition made u/s 69 regarding unexplained investment, as the assessee had duly explained their share of the investment, while leaving the issue of unsecured loan and jewellery amount received by the assessee's wife to be examined separately.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
