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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.
ITAT quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.
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