Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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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