Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
HC quashed reassessment under Section 148 where the only basis was an entry in a broker's seized inquiry register. The Court held that seized material must have a live nexus with the assessee and must pertain to or relate to the assessee; here, the entry pre-dated the purchase by nearly twenty-three months, referred to lands available for sale, covered multiple survey numbers and a larger area, and named another person. On these facts, the register entry could not support a presumption of escapement of income, and the reopening was based on conjectures and surmises. The notice for the assessment year 2021-22 was quashed.
HC quashed reassessment under Section 148 where the only basis was an entry in a broker's seized inquiry register. The Court held that seized material must have a live nexus with the assessee and must pertain to or relate to the assessee; here, the entry pre-dated the purchase by nearly twenty-three months, referred to lands available for sale, covered multiple survey numbers and a larger area, and named another person. On these facts, the register entry could not support a presumption of escapement of income, and the reopening was based on conjectures and surmises. The notice for the assessment year 2021-22 was quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
