Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
A reassessment based on alleged escapement of interest income could not be sustained when no addition was ultimately made on that recorded ground and the Assessing Officer instead disallowed loan processing fees, an item outside the reopening reasons. Applying Jet Airways, the Tribunal held that once the recorded basis for reopening failed, the officer could not independently assess a different issue without a fresh reopening notice. The addition was therefore deleted for want of jurisdictional foundation, and the assessee's appeal was allowed.
A reassessment based on alleged escapement of interest income could not be sustained when no addition was ultimately made on that recorded ground and the Assessing Officer instead disallowed loan processing fees, an item outside the reopening reasons. Applying Jet Airways, the Tribunal held that once the recorded basis for reopening failed, the officer could not independently assess a different issue without a fresh reopening notice. The addition was therefore deleted for want of jurisdictional foundation, and the assessee's appeal was allowed.
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