Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
The SC dismissed the Revenue's Special Leave Petition challenging the reopening of assessment under section 133A based on a survey of a bank. The petitioner's transactions with the bank involved inward and outward remittances, with discrepancies arising from the bank's use of both notional and actual realized exchange rates. The HC found that the petitioner had furnished all relevant material during the regular assessment, including bank statements reflecting actual realized rates, negating any prima facie belief of income escapement. The SC noted an unexplained inordinate delay of 198 days in filing and 79 days in refiling the SLP. On both procedural delay and substantive grounds, the SC upheld the High Court's order, concluding there was no justification to interfere with the assessment reopening. The petition was accordingly dismissed.
The SC dismissed the Revenue's Special Leave Petition challenging the reopening of assessment under section 133A based on a survey of a bank. The petitioner's transactions with the bank involved inward and outward remittances, with discrepancies arising from the bank's use of both notional and actual realized exchange rates. The HC found that the petitioner had furnished all relevant material during the regular assessment, including bank statements reflecting actual realized rates, negating any prima facie belief of income escapement. The SC noted an unexplained inordinate delay of 198 days in filing and 79 days in refiling the SLP. On both procedural delay and substantive grounds, the SC upheld the High Court's order, concluding there was no justification to interfere with the assessment reopening. The petition was accordingly dismissed.
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