Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.
Reassessment requires the Assessing Officer to assess or reassess the income forming the recorded basis for reopening before making additions for any other escaped income identified during the proceedings. The provision allowing assessment of other escaped income permits consideration of a new issue but does not remove this prerequisite. Where no addition or adverse finding was made regarding the recorded underpricing of a share transfer, an addition for unexplained credit arising from a separate share-sale transaction could not be made independently. A fresh reopening notice was required. The reassessment was therefore without jurisdiction and non est, while the merits of the addition remained unadjudicated.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
