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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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The HC held that the Assessing Officer's (AO) reopening of assessment under Section 147 was invalid. The AO's notice under Section 148A(d) exceeded the scope of original information, which suggested potential escaped income. The Assessee provided satisfactory explanations regarding TCS collection, cash deposits during demonetization, and time deposits. The court found no substantive evidence to support the reopening of assessment, thus setting aside the impugned notice and order. The decision emphasizes procedural fairness and the need for precise jurisdictional basis when reassessing tax liabilities.
The HC held that the Assessing Officer's (AO) reopening of assessment under Section 147 was invalid. The AO's notice under Section 148A(d) exceeded the scope of original information, which suggested potential escaped income. The Assessee provided satisfactory explanations regarding TCS collection, cash deposits during demonetization, and time deposits. The court found no substantive evidence to support the reopening of assessment, thus setting aside the impugned notice and order. The decision emphasizes procedural fairness and the need for precise jurisdictional basis when reassessing tax liabilities.
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