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...
Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.
Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
