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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Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
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