Timely pronouncement of reserved judgments requires defined timelines, transparency measures, and remedial pathways to protect liberty and effective j...
Settlement-price depression requires proof of manipulation, not merely short exposure, late selling, or below-market orders, preserving disclosure pen...
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...
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Search-related information concerning alleged non-genuine purchases must be addressed through the statutory reassessment route applicable where material is found in another person's search. The ordinary procedure under section 148A cannot displace that route. Approval for an order under section 148A(d) does not substitute for the independent prior approval required before issuing a notice under section 148. Compliance with the prescribed jurisdictional procedure is mandatory, not procedural; non-compliance creates a foundational jurisdictional defect and renders the reassessment notice and consequential assessment liable to be quashed without determination of the underlying addition.
Search-related information concerning alleged non-genuine purchases must be addressed through the statutory reassessment route applicable where material is found in another person's search. The ordinary procedure under section 148A cannot displace that route. Approval for an order under section 148A(d) does not substitute for the independent prior approval required before issuing a notice under section 148. Compliance with the prescribed jurisdictional procedure is mandatory, not procedural; non-compliance creates a foundational jurisdictional defect and renders the reassessment notice and consequential assessment liable to be quashed without determination of the underlying addition.
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