S. 147: Reassessment-Provision of certain amount towards restatement of liability in foreign currency-Reassessment is valid Finding of fact given by Tribunal cannot be disturbed in appeal before the High Court.[S.37(1), 148, 254(1), 260A]
S. 147: Reassessment-Provision of certain amount towards restatement of liability in foreign currency-Reassessment is valid Finding of fact given by Tribunal cannot be disturbed in appeal before the High Court.[S.37(1), 148, 254(1), 260A]
S. 147 : Reassessment –With in four years-Purchase and sale of land-Audit objection-Business income or capital gains-No fresh, tangible information-Reassessment notice and order disposing the objection is quashed.[S.28(i), 45, 148, Art. 226]
S. 147 : Reassessment-Long term capital gain-Limited scrutiny-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S.54F,143(3), 148, Art. 226]
S.147: Reassessment-After the expiry of four years-Capital asset –Agricultural land-Agricultural and situated beyond municipal limits, same did not come within ambit of section 2(14)(iii)(a)-No capital gain is liable to be taxed.[S. 2(14)(iii)(a), 45, 143(3), 144, 148, Art. 226]
S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-G.P rate of unrecorded transactions were recorded at 7.5% as against G.P rate of 12.5 % in respected recorded transactions-Reassessment notice and order disposing the objection is quashed. [S.143(3), 148, Art. 226]
S.147: Reassessment-After the expiry of four years-Bogus bills-Accommodation entries-Book profit-Adding the amount calculated by Assessing Officer towards escaped income amount computed under ordinary provision of Act amounted would be less than the amount paid as per book profit-Notice and order disposing the objection is quashed. [S.115JB,143(3), 148, Art. 226]
S.147: Reassessment-After the expiry of four years-notice under section 148 issued to examine the issue already verified during the course of assessment proceedings-No failure on the part of assessee-Notice is invalid.[S.28(i), 148, Art.226]
S.147: Reassessment-After the expiry of four years-Agricultural land-Capital gains-No new tangible materials or evidences-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S. 45, 54B,54F, 143(3), 148, Art. 226]
S.147: Reassessment-After the expiry of four years-Cash credits-Notice under section 148 issued relying on the information received from investigation wing without making any further inquiry-Notice is void ab initio.[S. 68, 148, Art.226]
S.147: Reassessment-After the expiry of four years-Business connection-Survey-Failure to deduct tax at source-Except for one, all other affiliates did not have a Permanent Establishment in India-Reassessment notice and order disposing the objection is quashed OECD Model Convention-Art. 5. [S.9(1)(i)),40(a(i), 133A, 148 195,201(1), Art. 226]