Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC held that the tax authority's reopening of assessment against the mutual fund was invalid. The notice contained discrepancies between alleged fund manipulation and actual transaction details. Relying on precedent in a similar case involving JM Financial, the court found no substantive basis for reassessment. The jurisdictional defect in the reopening process rendered the Section 148A notice and subsequent order unsustainable. Consequently, the impugned notice and order were quashed, effectively allowing the assessee's appeal and nullifying the attempted reassessment.
HC held that the tax authority's reopening of assessment against the mutual fund was invalid. The notice contained discrepancies between alleged fund manipulation and actual transaction details. Relying on precedent in a similar case involving JM Financial, the court found no substantive basis for reassessment. The jurisdictional defect in the reopening process rendered the Section 148A notice and subsequent order unsustainable. Consequently, the impugned notice and order were quashed, effectively allowing the assessee's appeal and nullifying the attempted reassessment.
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