Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
The HC dismissed the challenge, holding that the assessee had disclosed acquisition of the foreign asset in the original returns for AY 2012-13 and 2013-14 and in the return filed under s.153A prior to issuance of any penalty notice; books of account corroborated the disclosure. Applying the principle that a return filed under s.153A qualifies as a return for purposes of s.139(1), the tribunal and commissioner correctly concluded there was no failure to disclose and that imposition of the Rs.10 lakh penalty was not warranted on account of a remediable technical formatting defect. No substantial question of law arises.
The HC dismissed the challenge, holding that the assessee had disclosed acquisition of the foreign asset in the original returns for AY 2012-13 and 2013-14 and in the return filed under s.153A prior to issuance of any penalty notice; books of account corroborated the disclosure. Applying the principle that a return filed under s.153A qualifies as a return for purposes of s.139(1), the tribunal and commissioner correctly concluded there was no failure to disclose and that imposition of the Rs.10 lakh penalty was not warranted on account of a remediable technical formatting defect. No substantial question of law arises.
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