SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.
The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
