Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
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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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