Mis-declaration and Concealment: confiscation affirmed, transaction value re-determined and mandatory penalty sustained; redemption allowed on payment...
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Rectification proceedings invoked to recompute depreciation were held beyond the scope of the apparent mistake remedy because such powers address only manifest errors on the record and not detailed re-assessment; consequence: rectification to re-compute depreciation is invalid. Reopening of assessment was invalidated where the reasons and supervisory approval relied on incorrect AY references and unchecked figures, demonstrating non-application of mind and reliance on irrelevant information; consequence: the reopening notice vitiated for want of proper jurisdictional foundation and in favour of the assessee.
Rectification proceedings invoked to recompute depreciation were held beyond the scope of the apparent mistake remedy because such powers address only manifest errors on the record and not detailed re-assessment; consequence: rectification to re-compute depreciation is invalid. Reopening of assessment was invalidated where the reasons and supervisory approval relied on incorrect AY references and unchecked figures, demonstrating non-application of mind and reliance on irrelevant information; consequence: the reopening notice vitiated for want of proper jurisdictional foundation and in favour of the assessee.
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