Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
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Reassessment beyond four years was invalid where the original scrutiny had specifically examined disallowance of expenditure relating to exempt income and the assessee had provided relevant particulars. The revenue neither alleged failure to disclose fully and truly all material facts nor identified tangible material obtained after the original assessment showing income had escaped assessment. Reopening on re-examination of the same assessment record constituted a change of opinion. The High Court quashed the reassessment notice and consequential orders.
Reassessment beyond four years was invalid where the original scrutiny had specifically examined disallowance of expenditure relating to exempt income and the assessee had provided relevant particulars. The revenue neither alleged failure to disclose fully and truly all material facts nor identified tangible material obtained after the original assessment showing income had escaped assessment. Reopening on re-examination of the same assessment record constituted a change of opinion. The High Court quashed the reassessment notice and consequential orders.
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