Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
HC held that writ petitions are disposed and directed procedural safeguards before initiation of reassessment under s.147/148A: the assessees must file their returns by 31.10.2025; within one week of filing the AO shall disclose by email the information relied upon to propose reassessment; assessees shall have two weeks to file objections by a prescribed/accessible mode; the AO shall pass a reasoned, speaking order on those objections within two further weeks and communicate it to the assessees; if reassessment is to be initiated, the first hearing date shall be fixed with at least 30 days' advance notice. The HC reaffirmed that precedential law and Article 141 mandate affording a minimal opportunity to object before reassessment is initiated.
HC held that writ petitions are disposed and directed procedural safeguards before initiation of reassessment under s.147/148A: the assessees must file their returns by 31.10.2025; within one week of filing the AO shall disclose by email the information relied upon to propose reassessment; assessees shall have two weeks to file objections by a prescribed/accessible mode; the AO shall pass a reasoned, speaking order on those objections within two further weeks and communicate it to the assessees; if reassessment is to be initiated, the first hearing date shall be fixed with at least 30 days' advance notice. The HC reaffirmed that precedential law and Article 141 mandate affording a minimal opportunity to object before reassessment is initiated.
Note: It is a system-generated summary and is for quick reference only.