International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Reassessment under s.147 was challenged on limitation under s.149(1), where the assessee had disclosed complete details of property investment made by her spouse and the alleged escapement did not reach the ₹50 lakh threshold. Applying the statutory scheme and precedent, the forum held that the AO must first demonstrably form a view, from record material, that income chargeable to tax of ₹50 lakh or more escaped assessment to invoke the extended time limit; otherwise, only clause (a) applies. As the assessee established that the escapement assumption exceeding ₹50 lakh was incorrect, the s.148 notice issued beyond three years was invalid and all consequential proceedings were void ab initio. - ITAT
Reassessment under s.147 was challenged on limitation under s.149(1), where the assessee had disclosed complete details of property investment made by her spouse and the alleged escapement did not reach the ₹50 lakh threshold. Applying the statutory scheme and precedent, the forum held that the AO must first demonstrably form a view, from record material, that income chargeable to tax of ₹50 lakh or more escaped assessment to invoke the extended time limit; otherwise, only clause (a) applies. As the assessee established that the escapement assumption exceeding ₹50 lakh was incorrect, the s.148 notice issued beyond three years was invalid and all consequential proceedings were void ab initio. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
