Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
HC dismissed the petition and upheld the reopening of assessment. The court held that s.149(1)(b) is a jurisdictional fact to be established before reopening for escaped income, and the impugned order rested on a reasonable belief formed after a s.133A survey. The petitioner may adduce ledger entries and material in the pending inquiry; disputed questions of fact (including whether Rs.1,50,50,000 related to advances or AY 2020-21 expenditure) preclude relief under extraordinary writ jurisdiction. The HC found pre-conditions under s.148A(b) satisfied and no jurisdictional error in the exercise under s.148A(d). Article 226 cannot correct intra-jurisdictional errors of law/fact; petition dismissed.
HC dismissed the petition and upheld the reopening of assessment. The court held that s.149(1)(b) is a jurisdictional fact to be established before reopening for escaped income, and the impugned order rested on a reasonable belief formed after a s.133A survey. The petitioner may adduce ledger entries and material in the pending inquiry; disputed questions of fact (including whether Rs.1,50,50,000 related to advances or AY 2020-21 expenditure) preclude relief under extraordinary writ jurisdiction. The HC found pre-conditions under s.148A(b) satisfied and no jurisdictional error in the exercise under s.148A(d). Article 226 cannot correct intra-jurisdictional errors of law/fact; petition dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
