Tag Archives: Delhi

Reopening Barred by Limitation under Section 149 Since Corrected Escaped Income Falls Below Statutory Fifty Lakh Threshold

By | July 11, 2026
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Reopening Barred by Limitation under Section 149 Since Corrected Escaped Income Falls Below Statutory Fifty Lakh Threshold Issue Whether the Assessing Officer was legally justified in issuing a reassessment notice under Section 148 beyond the normal limitation period for an alleged income escape of Rs. 70 lakhs, when a proper evaluation of the transaction records… Read More »

High Court precedent binds TPO on comparables, while healthcare and IT services are functionally distinct from market research.

By | June 19, 2026
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High Court precedent binds TPO on comparables, while healthcare and IT services are functionally distinct from market research. Issue Whether the Transfer Pricing Officer (TPO) is justified in selectively applying filters and excluding historically accepted comparables despite binding High Court precedents, and whether software depreciation (60% vs 25%) and international travel expense disallowances warrant fresh… Read More »

Unexplained Bank Deposits Remanded for Fresh Assessment to Evaluate Profit Estimation Based on Past and Succeeding Years

By | June 11, 2026
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Unexplained Bank Deposits Remanded for Fresh Assessment to Evaluate Profit Estimation Based on Past and Succeeding Years Unexplained Bank Deposits Remanded for Fresh Assessment to Evaluate Profit Estimation Based on Past and Succeeding Years Issue Whether the Assessing Officer was justified in treating the entire cash deposit of ₹1.28 crore as unexplained money under Section… Read More »