SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
ITAT held that notices issued under section 148 and section 148A(b) by the jurisdictional assessing officer, instead of the faceless assessing officer, are invalid and set aside; consequent reassessment orders premised on such notices are quashed. The Tribunal further determined that where the assessing officer, in reassessment proceedings, made no addition on the very issue forming the basis for reopening, the officer lacked jurisdiction to make other additions, rendering the reassessment void. Parties were granted liberty to seek revival of the appeal should controlling decisions of higher courts on the faceless-notice issue necessitate modification of this order.
ITAT held that notices issued under section 148 and section 148A(b) by the jurisdictional assessing officer, instead of the faceless assessing officer, are invalid and set aside; consequent reassessment orders premised on such notices are quashed. The Tribunal further determined that where the assessing officer, in reassessment proceedings, made no addition on the very issue forming the basis for reopening, the officer lacked jurisdiction to make other additions, rendering the reassessment void. Parties were granted liberty to seek revival of the appeal should controlling decisions of higher courts on the faceless-notice issue necessitate modification of this order.
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