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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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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