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...
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The dominant issue was whether a reassessment notice under s.148 could be issued by a jurisdictional AO despite s.151A and the notified faceless regime mandating issuance only by the designated faceless authority. Relying on a co-ordinate bench decision holding that such notices issued by an AO lacked jurisdiction in view of s.151A and the applicable notification, the impugned s.148 notice and consequential assessment orders were set aside. The pending appellate proceedings were directed to be closed with liberty to either side to seek revival/restoration if circumstances so require. - HC
The dominant issue was whether a reassessment notice under s.148 could be issued by a jurisdictional AO despite s.151A and the notified faceless regime mandating issuance only by the designated faceless authority. Relying on a co-ordinate bench decision holding that such notices issued by an AO lacked jurisdiction in view of s.151A and the applicable notification, the impugned s.148 notice and consequential assessment orders were set aside. The pending appellate proceedings were directed to be closed with liberty to either side to seek revival/restoration if circumstances so require. - HC
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