Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
HC invalidated reassessment proceedings against the petitioner under Section 148A, finding a critical procedural defect. The AO's notice failed to substantiate the claim of a permanent establishment (PE) in India as originally proposed. The court determined that the grounds for issuing the reassessment notice did not align with the initial information provided, rendering the entire proceeding legally unsustainable. Consequently, the court set aside the notice under Sections 148, 148A(b), and 148A(d), effectively ruling in favor of the assessee and nullifying the tax department's reassessment attempt.
HC invalidated reassessment proceedings against the petitioner under Section 148A, finding a critical procedural defect. The AO's notice failed to substantiate the claim of a permanent establishment (PE) in India as originally proposed. The court determined that the grounds for issuing the reassessment notice did not align with the initial information provided, rendering the entire proceeding legally unsustainable. Consequently, the court set aside the notice under Sections 148, 148A(b), and 148A(d), effectively ruling in favor of the assessee and nullifying the tax department's reassessment attempt.
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TaxTMI 
TaxTMI 
