Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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HC held that the AO's reassessment notice under Section 147 was invalid. The AO mechanically recorded reasons based on third-party information without providing substantive evidence directly linking the petitioner to any undisclosed income. The court found no material connection between the survey operation and the petitioner's transactions. The AO's refusal to disclose confidential information to the assessee violated procedural fairness, rendering the reopening of assessment arbitrary and illegal. Consequently, the court quashed the reassessment notice, deciding in favor of the assessee and emphasizing the need for concrete, specific reasons when initiating reassessment proceedings.
HC held that the AO's reassessment notice under Section 147 was invalid. The AO mechanically recorded reasons based on third-party information without providing substantive evidence directly linking the petitioner to any undisclosed income. The court found no material connection between the survey operation and the petitioner's transactions. The AO's refusal to disclose confidential information to the assessee violated procedural fairness, rendering the reopening of assessment arbitrary and illegal. Consequently, the court quashed the reassessment notice, deciding in favor of the assessee and emphasizing the need for concrete, specific reasons when initiating reassessment proceedings.
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