Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The High Court held that the reopening of assessment u/s 147 did not violate the provisions of Section 148A. The respondents provided the petitioners an opportunity of being heard as specified in the order. The court found that the impugned orders mentioned the non-genuine accommodation entries made by Shri Ashok Kumar Gupta through various firms controlled by him, including M/s Kalki Trading Company and M/s Swastik Traders. The petitioners admitted transactions with these firms, involving the purchase and sale of commodities on the same day, indicating paper transactions. The court opined that the impugned orders u/s 148A(d) did not violate Section 148A, and the transactions being bogus, the petitioners' contentions regarding sale and not purchase lost their effect. The impugned orders did not fall within the exceptions settled by the Supreme Court in Godrej Sara Lee case.
The High Court held that the reopening of assessment u/s 147 did not violate the provisions of Section 148A. The respondents provided the petitioners an opportunity of being heard as specified in the order. The court found that the impugned orders mentioned the non-genuine accommodation entries made by Shri Ashok Kumar Gupta through various firms controlled by him, including M/s Kalki Trading Company and M/s Swastik Traders. The petitioners admitted transactions with these firms, involving the purchase and sale of commodities on the same day, indicating paper transactions. The court opined that the impugned orders u/s 148A(d) did not violate Section 148A, and the transactions being bogus, the petitioners' contentions regarding sale and not purchase lost their effect. The impugned orders did not fall within the exceptions settled by the Supreme Court in Godrej Sara Lee case.
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