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Commissioner of Income Tax-III, Hyderabad. Versus LGE & C-NCC (Joint Venture)

2014 (6) TMI 996 - ANDHRA PRADESH HIGH COURT

Initiating of proceedings u/s 147 - international transaction as identified as sham - assessment beyond ordinary period - Held that:- In case of assessment in relation to the present assessment year 2003-2004, it should be by the end of financial yea .....

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en no factual basis as required under the aforesaid provision to reopen the assessment beyond four years and within six years, meaning thereby pre-conditions for issuance of notice after four years and within six years, namely, the allegation of esca .....

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for its assessment for that assessment year have not been fulfilled. When pre-conditions are not found in the notices, initiation of proceedings is bad. We cannot re-appreciate this finding in the absence of the allegation of perversity. - Decided in .....

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ce Sri Kalyan Jyoti Sengupta) This appeal is sought to be preferred and admitted against the judgment and order dated 23.08.2013 of the learned Tribunal in relation to the assessment years 2003-2004 and 2004-2005 on the following suggested questions .....

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said assessment order which was upheld by the learned Commissioner of Income Tax (Appeals) only on the sole ground that the Transfer Pricing Officer (TPO) is not empowered to hold the international transactions of the respondent-assessee as sham tran .....

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national transaction which was identified as sham is the basis for reopening and this information was available consequent to the Transfer Pricing Officer s order? It appears that the Assessing Officer wanted to reopen the assessment in relation to t .....

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ant assessment year. In case of assessment in relation to the present assessment year 2003-2004, it should be by the end of financial year 2008, while for the year 2004-2005, it should be by the end of financial year 2009. Before us, copies of such n .....

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