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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ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
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