Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Reopening after four years requires fresh tangible material and satisfaction of the proviso to section 147; a reassessment cannot rest on a mere change of opinion. Audit objections led the Assessing Officer to re-examine balance-sheet documents and records already available during the original assessment, without new evidence or information indicating escaped income. The Tribunal quashed the reassessment for lack of jurisdiction. High Court found no substantial question of law, affirming that the Assessing Officer could not reopen the assessment solely through reappraisal of existing material beyond the four-year period.
Reopening after four years requires fresh tangible material and satisfaction of the proviso to section 147; a reassessment cannot rest on a mere change of opinion. Audit objections led the Assessing Officer to re-examine balance-sheet documents and records already available during the original assessment, without new evidence or information indicating escaped income. The Tribunal quashed the reassessment for lack of jurisdiction. High Court found no substantial question of law, affirming that the Assessing Officer could not reopen the assessment solely through reappraisal of existing material beyond the four-year period.
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