Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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AO reopened assessment beyond 4 year period without establishing assessee failed to truly disclose material facts. ITAT quashed reopening, holding AO merely changed opinion without tangible belief of escaped income. PCIT's revision u/s 263 to assess other income was rejected as show-cause didn't specify impugned order date, making action time-barred. Further, PCIT couldn't conclude assessment erroneous for non-consideration of information already possessed by AO while forming reopening belief. Assessee's appeal allowed by ITAT.
AO reopened assessment beyond 4 year period without establishing assessee failed to truly disclose material facts. ITAT quashed reopening, holding AO merely changed opinion without tangible belief of escaped income. PCIT's revision u/s 263 to assess other income was rejected as show-cause didn't specify impugned order date, making action time-barred. Further, PCIT couldn't conclude assessment erroneous for non-consideration of information already possessed by AO while forming reopening belief. Assessee's appeal allowed by ITAT.
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