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AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Reassessment beyond three years under section 149(1)(b) was unavailable because the Assessing Officer did not possess material showing escapement of income represented in the form of an asset of fifty lakh rupees or more. The order under section 148A(d) was found non-speaking, as it failed to explain why the housing loan sanction letter, bank statements and other supporting documents were unacceptable; the property purchase was substantially explained by the loan, and any remaining unexplained amount stayed below the statutory threshold. The notice under section 148 was therefore barred by limitation, the reopening was treated as a roving and fishing enquiry, and the section 148A(d) order, notice under section 148, and consequential assessment under section 147 were quashed.
Reassessment beyond three years under section 149(1)(b) was unavailable because the Assessing Officer did not possess material showing escapement of income represented in the form of an asset of fifty lakh rupees or more. The order under section 148A(d) was found non-speaking, as it failed to explain why the housing loan sanction letter, bank statements and other supporting documents were unacceptable; the property purchase was substantially explained by the loan, and any remaining unexplained amount stayed below the statutory threshold. The notice under section 148 was therefore barred by limitation, the reopening was treated as a roving and fishing enquiry, and the section 148A(d) order, notice under section 148, and consequential assessment under section 147 were quashed.
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