Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
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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