Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
For reopening beyond three years, the statutory threshold under section 149(1)(b) must be met by material showing escaped income of Rs. 50 lakhs or more. The Tribunal held that the reopening was initiated on incorrect or non-existing portal information, because the assessment ultimately treated only Rs. 17,17,597 as unexplained after verification and explanation by the assessee. As the case did not satisfy the extended-limitation condition, it fell within section 149(1)(a) and the notice under section 148 issued beyond three years was invalid. The consequential reassessment order under section 147 read with section 144B was quashed as void ab initio.
For reopening beyond three years, the statutory threshold under section 149(1)(b) must be met by material showing escaped income of Rs. 50 lakhs or more. The Tribunal held that the reopening was initiated on incorrect or non-existing portal information, because the assessment ultimately treated only Rs. 17,17,597 as unexplained after verification and explanation by the assessee. As the case did not satisfy the extended-limitation condition, it fell within section 149(1)(a) and the notice under section 148 issued beyond three years was invalid. The consequential reassessment order under section 147 read with section 144B was quashed as void ab initio.
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