Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
ITAT held that reopening of assessment u/s 147 beyond 3 years is impermissible when tax evasion does not exceed Rs. 50,00,000. Relying on precedents from Delhi HC and Bombay HC, the tribunal quashed the reassessment notice u/s 148A(d) and 148, finding the proceedings invalid. The AO's best judgment assessment, which added unexplained investment and stamp duty value differences, was set aside. The assessee's appeal was allowed, rendering subsequent grounds academic, effectively nullifying the extended assessment proceedings.
ITAT held that reopening of assessment u/s 147 beyond 3 years is impermissible when tax evasion does not exceed Rs. 50,00,000. Relying on precedents from Delhi HC and Bombay HC, the tribunal quashed the reassessment notice u/s 148A(d) and 148, finding the proceedings invalid. The AO's best judgment assessment, which added unexplained investment and stamp duty value differences, was set aside. The assessee's appeal was allowed, rendering subsequent grounds academic, effectively nullifying the extended assessment proceedings.
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