Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
HC quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee.
HC quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
