Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.
Reassessment based on information linked to GST adjudication requires independent application of the Income-tax Act. Information suggesting escaped income may include material obtained through a CBDT risk-management strategy, but the record must establish that the relevant strategy covers the GST adjudication order. Income-tax authorities cannot rely solely on the GST proceeding or its appellate outcome when issuing or pursuing reassessment. The reassessment notice remained undisturbed, while any reassessment was required to proceed independently under the Income-tax Act and remain open to subsequent challenge.
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