Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
Reopening under section 147 was held invalid where recomputation of depreciation would not alter the assessee's tax liability under the MAT regime. The infrastructure business was already entitled to full deduction on profits, and any higher depreciation rate would only reduce normal income without affecting the book profit taxed under section 115JB. Because the depreciation particulars were already disclosed in the original scrutiny assessment, the attempt to reopen on the same material amounted to a mere change of opinion. The notice and reassessment order were quashed for want of any escapement of income chargeable to tax.
Reopening under section 147 was held invalid where recomputation of depreciation would not alter the assessee's tax liability under the MAT regime. The infrastructure business was already entitled to full deduction on profits, and any higher depreciation rate would only reduce normal income without affecting the book profit taxed under section 115JB. Because the depreciation particulars were already disclosed in the original scrutiny assessment, the attempt to reopen on the same material amounted to a mere change of opinion. The notice and reassessment order were quashed for want of any escapement of income chargeable to tax.
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