Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
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The proviso to Section 270AA(4) bars rejection of a penalty-immunity application without a meaningful opportunity of hearing. Notice requiring appearance on the following day, followed by immediate rejection, was insufficient to allow applicants to present and substantiate their claims. The rejection orders were set aside, and the applications were remitted for fresh consideration after hearing the applicants and considering their material. Assessing Authorities were entitled to await expiry of the prescribed appeal period before deciding the applications; that delay did not invalidate the process.
The proviso to Section 270AA(4) bars rejection of a penalty-immunity application without a meaningful opportunity of hearing. Notice requiring appearance on the following day, followed by immediate rejection, was insufficient to allow applicants to present and substantiate their claims. The rejection orders were set aside, and the applications were remitted for fresh consideration after hearing the applicants and considering their material. Assessing Authorities were entitled to await expiry of the prescribed appeal period before deciding the applications; that delay did not invalidate the process.
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