Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Reassessment proceedings were held to be within limitation because the first corrigendum to the section 148A(b) notice validly extended the time to respond, and that extended period had to be excluded under the third proviso to section 149(1). On that basis, the section 148A(d) order and section 148 notice were timely, and approval by the PCIT/CIT was competent rather than approval by the PCCIT/CCIT. The objection that only the Faceless Assessing Officer could issue the notice was rejected, as both the jurisdictional and faceless officers were treated as competent. The writ challenge on disputed factual issues, including claimed tax exemption and NRE account status, was not entertained, leaving those matters for the Assessing Officer.
Reassessment proceedings were held to be within limitation because the first corrigendum to the section 148A(b) notice validly extended the time to respond, and that extended period had to be excluded under the third proviso to section 149(1). On that basis, the section 148A(d) order and section 148 notice were timely, and approval by the PCIT/CIT was competent rather than approval by the PCCIT/CCIT. The objection that only the Faceless Assessing Officer could issue the notice was rejected, as both the jurisdictional and faceless officers were treated as competent. The writ challenge on disputed factual issues, including claimed tax exemption and NRE account status, was not entertained, leaving those matters for the Assessing Officer.
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