Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Transitional reassessment notices must be issued within the surviving limitation available under the legal fiction, after prescribed exclusions. Where the new-regime notice is issued after that period, the resulting reassessment is void from inception, non est and incapable of revision because a valid subsisting assessment is a condition precedent for revision. Revision also requires both an erroneous assessment and prejudice to Revenue. Inquiry into exempt long-term capital gains supported by transaction records, contract notes, demat evidence, banking trail and securities transaction tax cannot be treated as erroneous merely because the inquiry was not extensively recorded or further inquiry is considered desirable.
Transitional reassessment notices must be issued within the surviving limitation available under the legal fiction, after prescribed exclusions. Where the new-regime notice is issued after that period, the resulting reassessment is void from inception, non est and incapable of revision because a valid subsisting assessment is a condition precedent for revision. Revision also requires both an erroneous assessment and prejudice to Revenue. Inquiry into exempt long-term capital gains supported by transaction records, contract notes, demat evidence, banking trail and securities transaction tax cannot be treated as erroneous merely because the inquiry was not extensively recorded or further inquiry is considered desirable.
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