S.147: Reassessment-After the expiry of four years- There was no failure to disclose material facts — Mere change of opinion — Notice s held to be not valid [ S.148 ]
S.147: Reassessment-After the expiry of four years- There was no failure to disclose material facts — Mere change of opinion — Notice s held to be not valid [ S.148 ]
S.147: Reassessment — -After the expiry of four years- Deemed dividend — No obligation to disclose when the assessee was not benefitted .[ S.2(22) ( e ) , 148, Art , 226 ]
S.147: Reassessment-After the expiry of four years- Purchasing non-performing asset from Bank and receiving payment -Alleged bogus entry provider – Reasons neither supported by an affidavit or oral submission — Notice is held go be invalid . [ S. 148 ]
S.144: Best judgment assessment – Bogus purchases -Hawala entries -Sales tax department – Income from undisclosed sources — Estimate of profits at 5% of bogus based is held to be justified [ S.142(1) ]
S.142(2A): Inquiry before assessment– Special audit– Limitation – Block assessment -Date of order on special audit to be taken and not date on which order was served on the assessee- Order is not barred by limitation . [ S.158BE ]
S. 133A :Power of survey -Rejection of books of account and estimation of income – Accommodation entries – Statement of director recorded two Thousand days after survey and not under oath – Merely on the basis of statement addition is held to be not valid [ S.144 ]
S.115QA: Tax on distributed income to share holders- Buy back of shares – Remittances to non-residents- Appeal pending before Supreme Court -Department agreeing to treat communication as show-cause notice — Direction to assessee to file reply thereto and further directions as to continuance of interim orders. [ S. 2(22) (a) , 2(22(d) , 115O, 245Q ]
S.115JB: Book profit – Interest – Retrospective amendment -Interest is leviable [ S.234B ]
S.115JB : Book profit – Insurance business — Accounts prepared in accordance with Insurance Act, 1938- Provision relating to books of account is not applicable [ Insurance Act , 1938 ]
S.92C:Transfer pricing- Arm’s length price —Appellate Tribunal- Advertising, marketing and publicity expenses —Remand by the Tribunal for determination of arm’s length price is held to be not warranted. [ S.254(1) ]