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...
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Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
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The ITAT held the reassessment order u/s 147/143(3) void ab initio due to jurisdictional defects. The notice was dispatched on 01.04.2014, rendering it time-barred beyond the 4-year limitation period. The tribunal found the assessee had fully disclosed material facts during original assessment proceedings, and the AO had already scrutinized all relevant information. Relying on SC precedent in Kelvinator case, the tribunal emphasized that reopening assessment cannot be a mere change of opinion. The AO's attempt to review was deemed an abuse of power, with the tribunal ultimately deciding in favor of the assessee.
The ITAT held the reassessment order u/s 147/143(3) void ab initio due to jurisdictional defects. The notice was dispatched on 01.04.2014, rendering it time-barred beyond the 4-year limitation period. The tribunal found the assessee had fully disclosed material facts during original assessment proceedings, and the AO had already scrutinized all relevant information. Relying on SC precedent in Kelvinator case, the tribunal emphasized that reopening assessment cannot be a mere change of opinion. The AO's attempt to review was deemed an abuse of power, with the tribunal ultimately deciding in favor of the assessee.
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