S. 148 : Reassessment-Amalgamation-Notice issued to non existing company-Non-est and void. [S. 147, Art. 226]
S. 148 : Reassessment-Amalgamation-Notice issued to non existing company-Non-est and void. [S. 147, Art. 226]
S. 147: Reassessment-Notice Issued on basis of information received from Deputy Director of Income-Tax (Investigation)-Non-application of mind-information received from the investigation wing-Reassessment invalid. [S. 68, 143(1), 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Capital gains-Capital work-in-progress-Investment in property is accepted in assessment-Reassessment notice and order disposing the objection is quashed.[S. 45, 148, Art. 226]
S. 147 : Reassessment-With in four years-General allegation-No violation of provisions of S. 11(3)(d)-Charitable purpose-Donation to hospital-No violation of provisions of sections 11(2), 11(3)(d) of the Act-SLP of Revenue is dismissed, order of High Court quashing the reassessment notice is affirmed. [S.10(23C), 11(2), 11(3(d), 12AA, 148, Art. 136]
S. 144C : Reference to dispute resolution panel-Assessment-Faceless assessment-Amendment with effect from 1-4-2020-Not a substantive provision-Machinery provision which has been incorporated for the benefit of the assessees including eligible assessee-Assessment proceedings after 1-4-2020, amendment is applicable-Assessment is held to be valid.[S.143(3), 144C(15)(b) (ii), Art. 226]
S. 144C: Reference to dispute resolution panel-Eligible assessee-Final assessment order as accompanied with demand and penalty notices-Order invalid.[S.144C(8), 144C(15), 260A]
S. 144B : Faceless Assessment-Reassessment-Alternative remedy-Question of fact-Writ petition is dismissed-Directed to file statutory appeal.[S. 69C,115BBE, 147, 148,246A, Art.226
S. 143(3) : Assessment-Income-Tax Authorities-High Court-Binding precedent-Decision of High Court is binding on Income-Tax Authorities-Order of Assessment ignoring direction of High Court is not valid [S. 56(2)(viib), Art. 215, 226, 227]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net margin method-Identical with earlier years-No substantial question of law. [S.260A]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Exclusion of companies large and with functional and segmental dissimilarities-Appreciation of facts-No substantial question of law.[S.92CA(3), 260A]