Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Page of 4826
Press 'Enter' after typing page number.
81 to 100 of 96510 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT allowed the assessee's appeal and quashed the reassessment. It held that the notice issued u/s 148 was unsigned and therefore non est in law, vitiating the entire reassessment order. ITAT further held that reassessment proceedings were invalid as reasons recorded for reopening were not supplied to the assessee before issuance of notice u/s 143(2), thereby denying the assessee its right to challenge jurisdiction and breaching mandatory procedural safeguards. On merits, ITAT deleted the addition u/s 68, noting that the assessee had discharged the onus by furnishing confirmations, ITR acknowledgments, bank statements and audited financials of the loan creditor, and had repaid the loan, which the AO and CIT(A) failed to properly consider.
ITAT allowed the assessee's appeal and quashed the reassessment. It held that the notice issued u/s 148 was unsigned and therefore non est in law, vitiating the entire reassessment order. ITAT further held that reassessment proceedings were invalid as reasons recorded for reopening were not supplied to the assessee before issuance of notice u/s 143(2), thereby denying the assessee its right to challenge jurisdiction and breaching mandatory procedural safeguards. On merits, ITAT deleted the addition u/s 68, noting that the assessee had discharged the onus by furnishing confirmations, ITR acknowledgments, bank statements and audited financials of the loan creditor, and had repaid the loan, which the AO and CIT(A) failed to properly consider.
Note: It is a system-generated summary and is for quick reference only.