Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
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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