Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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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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