Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Once an application under section 220(6) of the Income-tax Act, 1961 was allowed and the assessee was treated as not in default, the consequential demand for the earlier assessment year stood stayed, and the revenue lacked authority to adjust refunds of a later assessment year against that stayed demand. As the assessee had already deposited more than 20% of the disputed tax to secure stay, the adjustment made from the refundable amount of the subsequent assessment year was held impermissible. The revenue was directed to refund the amount adjusted pursuant to the intimation, excluding the amount deposited for stay, within the stipulated time. - HC
Once an application under section 220(6) of the Income-tax Act, 1961 was allowed and the assessee was treated as not in default, the consequential demand for the earlier assessment year stood stayed, and the revenue lacked authority to adjust refunds of a later assessment year against that stayed demand. As the assessee had already deposited more than 20% of the disputed tax to secure stay, the adjustment made from the refundable amount of the subsequent assessment year was held impermissible. The revenue was directed to refund the amount adjusted pursuant to the intimation, excluding the amount deposited for stay, within the stipulated time. - HC
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