Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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HC set aside the reassessment proceedings and quashed the sanction under section 151 insofar as they pertain to the Petitioner, holding that no income chargeable to tax has escaped assessment. The court found the asserted "reasons to believe" unsupported by cogent material: the investigation report did not list the Petitioner as a beneficiary of accommodation entries and the contested transactions were sales proceeds already offered to tax. The reasons recorded misidentified another assessee and, together with uncorrected supervisory review, demonstrated a mechanical, non-application of mind in granting sanction. Consequently, reopening was held invalid and the Petitioner succeeded.
HC set aside the reassessment proceedings and quashed the sanction under section 151 insofar as they pertain to the Petitioner, holding that no income chargeable to tax has escaped assessment. The court found the asserted "reasons to believe" unsupported by cogent material: the investigation report did not list the Petitioner as a beneficiary of accommodation entries and the contested transactions were sales proceeds already offered to tax. The reasons recorded misidentified another assessee and, together with uncorrected supervisory review, demonstrated a mechanical, non-application of mind in granting sanction. Consequently, reopening was held invalid and the Petitioner succeeded.
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