Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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Reopening based on audit objections and issues already examined in scrutiny assessment was treated as a mere change of opinion, because the Assessing Officer had raised specific queries in the original proceedings and the assessee had disclosed full particulars. The reassessment was held invalid on depreciation claims for computers, plant and machinery, goodwill, CSR-linked deduction under Chapter VI-A, and excess discount provision, since each issue had been considered earlier or lacked a live nexus with any new material. The recorded reasons were also found vague on excess depreciation and contrary to the statutory scheme on additional depreciation and goodwill. On that basis, the notice under section 148 and the order rejecting objections were quashed.
Reopening based on audit objections and issues already examined in scrutiny assessment was treated as a mere change of opinion, because the Assessing Officer had raised specific queries in the original proceedings and the assessee had disclosed full particulars. The reassessment was held invalid on depreciation claims for computers, plant and machinery, goodwill, CSR-linked deduction under Chapter VI-A, and excess discount provision, since each issue had been considered earlier or lacked a live nexus with any new material. The recorded reasons were also found vague on excess depreciation and contrary to the statutory scheme on additional depreciation and goodwill. On that basis, the notice under section 148 and the order rejecting objections were quashed.
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