Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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...
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A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not substitute recording satisfaction note by AO and handing over material for initiation of proceedings u/s 153C. No reference of asset representing escaped income, hence reopening for ten years u/s 153A not applicable. Notice issued beyond six years from end of AY 2014-15, beyond limitation period. HC allowed petition, set aside impugned notices u/s 148A(b) and 148, decided in favour of assessee.
A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not substitute recording satisfaction note by AO and handing over material for initiation of proceedings u/s 153C. No reference of asset representing escaped income, hence reopening for ten years u/s 153A not applicable. Notice issued beyond six years from end of AY 2014-15, beyond limitation period. HC allowed petition, set aside impugned notices u/s 148A(b) and 148, decided in favour of assessee.
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