S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Bank account was opened without his knowledge-Disputed questions of fact-Writ petition is dismissed. [S. 148, 148A(b), 148A(d), Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Bank account was opened without his knowledge-Disputed questions of fact-Writ petition is dismissed. [S. 148, 148A(b), 148A(d), Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Information which was relied upon by revenue was not completely furnished-Notice and order disposing the objection is quashed and set aside. [S. 148, 148A(b), 148A(d), Art.226]
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amount received from sale/resale of shrink-wrapped software-Not royalty or Fees for technical services-Reassessment notice and order disposing the objection is quashed-DTAA-India-Japan. [S. 9(1)(vi), 9(1)(vii), 148A(b), 148A(d),art.5 Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Foreign companies-company is a resident of Singapore-Investment in Indian subsidiary-Tax on dividends, royalty and technical services-Capital account transaction-Investments could not be treated as income as same was in nature of capital account transaction not giving rise to any income[S.9(1)((i), 115A, 148A(b), 148A(d), Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Information from DDIT(Investigation)-Reassessment notice was quashed by High court-Delay of 399 days-SLP of Revenue is dismissed delay was not sufficiently explained. [S. 68, 147, 148, 148A(b), 148A(d), Art. 136]
S. 147 : Reassessment-Interest paid and received-Capital receipt-Change of opinion-Reassessment is bad in law. [S. 4, 36(1)(iii), 148, 260A]
S. 147 : Reassessment-With in four years-Donation-CSR expenditure-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S. 37(1), 80G, 147, 148, Art. 226]
S.147: Reassessment-After the expiry of four years-Amalgamation-Reassessment orders passed under section 144 read with section 147 in name of non-existing entity is quashed and set aside.[S. 144, 148, 292B, Art. 226]
S. 144C : Reference to dispute resolution panel-Appellate Tribunal-Remand-Even in partial remand proceedings from Tribunal, Assessing Officer is obliged to pass a draft assessment order under section 144C(1).[S.92CA(3), 144C(1), Art. 226]
S. 144B :Faceless Assessment-Draft assessment order-Principle of natural justice-Order is passed without considering the reply-Matter remanded to the Assessing Officer. [S. 144C, Art. 226]