S. 220 : Collection and recovery-Assessee deemed in default-Pendency of appeal-Purchase transaction-Bogus purchase-Not liable to submit seller’s stock register-Not liable to pay 25 Per Cent of demand.[S. 37, 156, 220(6), 250, Art. 226]
S. 220 : Collection and recovery-Assessee deemed in default-Pendency of appeal-Purchase transaction-Bogus purchase-Not liable to submit seller’s stock register-Not liable to pay 25 Per Cent of demand.[S. 37, 156, 220(6), 250, Art. 226]
S. 153A: Assessment-Search-Reassessment-Completed or unabated assessments-Limitation-Liberty given to Revenue cannot be construed to have given liberty to Revenue from obligation to establish that reassessment proceedings are otherwise in accordance with law-Reassessment notice under section 148 and the consequential proceedings under section 147 were quashed. [S. 132, 147,148, 149(1), 150, 153C, Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notices and orders not mentioning name and designation of concerned officers-Notices and orders are set aside.[S. 147, 148, 148A(b), 148A(d), 282A, Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Sufficient opportunity to be heard is not given-Order is not valid [S. 147, 148, 148A(b), 148A(d), Art. 226]
S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is not valid. [S. 148, Art. 226]
S. 145 : Method of accounting-Rejection of accounts-Rule of consistency-Offering income to tax in year in which services rendered-Tax rate same and no loss to revenue-Rejection of books of account is not justified. [S. 260A]
S. 143(3): Assessment-Natural justice-24 hours time to respond notice-No adequate opportunity to respond to notice-Assessment order is quashed and set aside-Matter remanded. [S. 144B, Art. 226]
S. 139 : Return of income-Delay in filing return-Limitation-Delay of five months-CBDT-Period to be computed with reference to date on which return had been filed -Refund – Order rejecting the application was set aside .[S.119(2)(b), 237 , Art. 226]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Comparable-Advertisement and marketing-No substantial question of law. [S.92CA, 260A]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-No substantial question of law.[S.260A]