RBI supersession powers over multi-State co-operative banks operate independently of the constitutional six-month ceiling and permit statutory extensi...
Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
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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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