Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Reassessment initiated beyond four years requires failure by the assessee to disclose fully and truly all material facts relating to the recorded escapement of income. Explanation 3 to section 147 permits assessment of other escaped income discovered during valid reassessment proceedings, but does not expand the jurisdictional basis for reopening or sustain proceedings when no addition is made on either recorded ground. Where the recorded reasons yield no addition and the requisite failure of disclosure is not established, the reopening lacks jurisdiction. The reassessment was quashed, and the Revenue's appeal was dismissed.
Reassessment initiated beyond four years requires failure by the assessee to disclose fully and truly all material facts relating to the recorded escapement of income. Explanation 3 to section 147 permits assessment of other escaped income discovered during valid reassessment proceedings, but does not expand the jurisdictional basis for reopening or sustain proceedings when no addition is made on either recorded ground. Where the recorded reasons yield no addition and the requisite failure of disclosure is not established, the reopening lacks jurisdiction. The reassessment was quashed, and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
