S.147: Reassessment- After the expiry of four years- No failure to disclose material facts- Notice to withdrawal of exemption is held to be not valid . [ S.10(15) (iv), S.148 ,154,Art , 226 ]
S.147: Reassessment- After the expiry of four years- No failure to disclose material facts- Notice to withdrawal of exemption is held to be not valid . [ S.10(15) (iv), S.148 ,154,Art , 226 ]
S.147: Reassessment- After the expiry of four years- No failure to furnish material facts necessary for assessment — Purchase and sale of shares- Audit objection – Reply by the Assessing Officer to drop the proceedings- Notice is held to be not valid [ S. 56 (2) (vii) (a),148 ]
S.147: Reassessment-After the expiry of four years- No failure to disclose material facts necessary for Assessment — Transfer of shares as gift – Change of opinion — Notice not valid [ S.45, 47, 148 ]
S.145: Method of accounting -Mercantile system of accounting—Accrual of income -Retention money on contract —Cannot be included income .[ S.4 , 5 ]
S. 144C : Reference to dispute resolution panel – Transfer pricing – Arm’s length price – Direction By Dispute Resolution Panel – Writ is not maintainable [ S.92C, Art. 136, 226 ]
S. 127 : Power to transfer cases – Transfer from Assessing Officer- Agreement between two higher authorities — Opportunity of hearing should be given . [ Art. 226 ]
S. 115JB : Book profit – Capital gains —Indexed cost of acquisition to be considered [ S.45 , 48 ]
S. 92C : Transfer pricing – Arm’s length price –Comparable uncontrolled price method or the transactional net margin method- Question of fact- Commission – Finding of fact . [ S.37(1) , 254(1) 260A ]
S. 92C : Transfer pricing – Arm’s length price – Instruction of CBDT is binding on revenue -Instruction No .3 of 2003 ( 2003 ) ( 261 ITR 51 (St) [ S.92CA ]
S. 92C : Transfer pricing – Arm’s length price – Internal transactional net margin method -Method adopted – No question of law [ S. 92 to 94B, 260A ]