Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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The HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.
The HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.
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