Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
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