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 ...
Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.
Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
