Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.
Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.
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